E-filing Asset Declarations Benefits and Challenges Dmytro Kotlyar Laura Pop  | 1  StAR-asset-disclosure-report-06-print.indd 1 5/21/19 5:09 PM © 2019 International Bank for Reconstruction and Development / The World Bank 1818 H Street NW, Washington, DC 20433 Telephone: 202-473-1000; Internet: www.worldbank.org Some rights reserved. StAR—the Stolen Asset Recovery Initiative—is a partnership between the World Bank Group and the United 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 of corruption and to facilitate more systematic and timely return of stolen assets. This work is a product of the staff of The World Bank with external contributions. 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Design by Sensical Design & Communication StAR-asset-disclosure-report-06-print.indd 2 5/21/19 5:09 PM Acknowledgments This study would not have been possible without the valuable contributions of Emilie Cazenave (International Partnerships Coordinator, High Authority of Transparency in Public Life, France) and Christopher J. Swartz (As- sociate Counsel and Team Leader, International Assistance and Outreach Program, Office of Government Ethics, United States). This study also benefited at the final review stage from the advice of Izadora Zubek (International Project Officer, High Authority of Transparency in Public Life, France). The authors would like to thank Ismail Radwan (Lead Public Sector Specialist, Governance Global Practice, World Bank Group), who supported this study from the conceptual stage through research and drafting. The authors benefited from the expert advice and guidance provided during the peer review process, which was chaired by Tatiana Proskuryakova (Country Manager for Romania, World Bank Group). The peer reviewers were: Alberto Leyton (Lead Public Sector Specialist, Governance Global Practice, WBG), Ivana Rossi (Senior Financial Sector Specialist, Stolen Asset Recovery Initiative/WBG) and Stephen Zimmermann (Senior Adviser, Governance Global Practice, WBG). The authors are also grateful to Satu Kähkönen (Country Director for Belarus, Moldova and Ukraine, WBG) and David Bernstein (Lead Public Sector Specialist, Governance Global Practice, WBG) for their contribution during the final review of country experiences. We would also like to gratefully acknowledge the support and leadership of Yira Mascaró (Practice Manager, Financial Integrity, WBG), Emile van der Does de Willebois (Lead Financial Sector Specialist and StAR Coordi- nator/WBG) and Roberto Senderowitsch (Practice Manager, Governance Global Practice, WBG). We would like to thank Tammar Berger (Consultant, WBG), Dmytro Chaplynskyi (Consultant, StAR) and Molly Jeannette Silver (Consultant, StAR) for their review and feedback on the content of the study at different stages of the drafting. Acknowledgments | 1 StAR-asset-disclosure-report-06-print.indd 1 5/21/19 5:09 PM About the Authors Dmytro Kotlyaris a consultant with the World Bank/Stolen Asset Recovery Initiative (StAR) since 2015. He focuses on asset declarations, conflict of interest, beneficial ownership, criminalization of corruption, e- governance and other related issues. He has more than 11 years of experience working on anticorruption and rule of law issues. He helped design and implement the electronic asset disclosure system in Ukraine and has advised other governments on anticorruption reforms. Dmytro has also worked as a consultant on anticorruption and good governance issues for other organizations and technical assistance projects, including OECD, Council of Europe, UNDP, EU, USAID. Working for the OECD Anticorruption Network for Eastern Europe and Central Asia, Dmytro led peer reviews of several countries in the region. Before that he worked as a Deputy Minister 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. Laura Popis a Senior Financial Sector Specialist with the World Bank Financial Market Integrity/Stolen Asset Recovery Initiative (StAR) team. Since joining the World Bank in 2009, she has advised countries on multiple areas of financial disclosure (enhancing the legal framework, using electronic tools, increasing the effectiveness of verification, operationalizing the concept of beneficial ownership in declarations, inter-agency cooperation) to more than 20 countries across all regions. She co-authored the StAR publication “Getting the Full Picture on Public Officials: A How to Guide for Effective Financial Disclosure” and the World Bank publication ”Using Asset Disclosure for Identifying Politically Exposed Persons.” She also advises and works on asset recovery and anti-money laundering programs at StAR and the World Bank. She holds a BA from Princeton University and an MA from Harvard University. 2  |  E-filing Asset Declarations: Benefits and Challenges StAR-asset-disclosure-report-06-print.indd 2 5/21/19 5:09 PM E-filing Asset Declarations Introduction The electronic disclosure systems can vary signifi- The disclosure of assets and interests by public officials cantly in functionality, design, level of complexity, or is increasingly common globally. According to World authentication methods. In some systems, declarations Bank research, more than 143 countries have introduced are simply collected, with no processes in place for data a system of asset and/or interest disclosure for public validation. There is also large variation in how systems officials.1 Asset and interest disclosure systems serve as authenticate the data. In some cases, digital signatures an important tool to prevent conflicts of interests and are used, while in others, authentication relies on a illicit enrichment, improve integrity, and promote ac- two-step process using cell-phone numbers. countability of public officials.2  While introducing a fully electronic submission While asset declaration systems differ in objectives, system can raise implementation challenges, the above scope of information disclosed, and range of filers with examples show that countries from all regions and an obligation to disclose, many share a recent transition income groups can succeed in making the transition. to the electronic filing of declarations.3 The challenges The challenges that may emerge (additional costs in and costs associated with managing a paper-based sys- the short term, the need for awareness raising and tem combined with the benefits of an electronic system training, etc.) are outweighed by the benefits of an are compelling. The transition to electronic-based filing electronic system. Even in the short term, the elec- and data management depends on many variables such tronic system will save financial and human resources as internet access, availability of digital signatures, infor- by eliminating the need for secure physical storage mation technology capacity, and institutional capacity space for a growing volume of declarations and al- to process electronic filings. lowing the staff of asset declaration agencies to focus The benefits are numerous: moving to an electronic on ensuring compliance and providing advice rather system allows for coverage of a broader scope of than sorting and organizing the paper declarations. declarants, simplifies the submission process by mak- E-filing also helps prevent numerous unintentional ing the declaration form more user-friendly, reduces mistakes caused by human error for which filers may the number of mistakes made in the forms, facilitates be held responsible. further analysis and verification of declarations, and The objective of this paper is to present an overview improves data management and security. Electronic of the benefits and challenges associated with transi- filing (E-filing) thus helps raise the level of compliance tioning from paper-based to electronic filing. While with submission requirements. Electronic systems also many of the experiences and practices presented can open new possibilities for disclosing data to the public be relevant to experts from countries across all regions and promoting better accountability and transparency. and income levels, the primary audience is policy- An increasing number of countries in various regions makers, asset declaration/anti-corruption experts, and have digitized their asset disclosure systems, including: practitioners in middle-income countries, with a focus Argentina, Bhutan, Chile, Costa Rica, Croatia, Estonia, on countries in Europe and Central Asia. The selec- France (see case-study), Georgia, Indonesia, Republic tion of examples included in this policy paper aims to of Korea, Kyrgyz Republic, Latvia, Lithuania, Mexico, present experiences from different regions and legal Moldova, Mongolia, Rwanda, Serbia, Slovenia, Uganda, systems: a European Union/OECD member (France), Ukraine (see case-study), and USA (see case-study). a lower middle-income country (Ukraine), and an E-filing Asset Declaration | 3 StAR-asset-disclosure-report-06-print.indd 3 5/21/19 5:09 PM OECD country (United States). This paper provides • There is the possibility to add notes to explain an overview of the topic and does not aim to discuss situations not fully covered by the form (i.e. when all technical issues exhaustively. the pre-determined fields in the form do not allow filers to adequately provide information about an The Benefits of Electronic Asset asset or interest). and Interest Disclosure • After submitting all data, the declarant can see an There are four main reasons for moving to electronic overview of all sections of the declaration form filing: and return to the form and edit certain sections if 1. Convenience for declarants; needed. 2. Better data management and improved security; • Filers can download and print electronic docu- ments submitted in the system. 3. More effective review and enforcement; and • Declarants can submit additional information (e.g. 4. Increased transparency and public accountability. explanations) or documents to the agency in charge of verification of declarations. 1. Convenience for declarants E-filing significantly simplifies and streamlines the pro- • The form may also have built-in tutorials and other cess of submitting declarations. Declarants do not have to explanatory and training materials that inform and deal with paper forms, which means declarants no longer educate filers about the process and guide them need to search for the forms online, download them, through each step. print or obtain them elsewhere as a hardcopy. In addition, electronic data can be easily corrected and supplemented. Better data management 2.  An electronic form provides a clean layout that is easy and increased security to navigate and use. The electronic form also guides the Managing paper-based asset disclosure systems can be declarant to enter correct data through various automated very resource and time intensive. Declarations need to be processes and thus minimizes errors that would require physically collected from across the country, organized additional time and resources to correct. by institution/region, kept in a secure facility designed to The benefits of an electronic system for the declarant prevent theft or tampering as well as any damage caused include: by the elements (ie moisture, heat, etc.) In some countries the paper forms are scanned for verification purposes and • Declarants can enter data in the electronic form at to make the content publicly available. any convenient time or place (e.g. from home or As noted in the Stolen Asset Recovery Initiative pub- work); they can save, update, and delete drafts lication “Getting the Full Picture on Public Officials: A before submitting; declarants can log out and log How-To Guide for Effective Financial Disclosure,”4 when in the system at any time. the number of filers is high, scanning can be very expen- • No paper forms need to be mailed, filed, or other- sive and resource intensive. Also, scanned forms limit the wise handed over physically. capacity to perform data analysis and the usability of the data when they become public. Both when declarations • There is the possibility to pre-populate the form are scanned and when the data is manually transferred with the previous data (use previous declaration as from paper declarations into an electronic database, stor- a draft of the new one) to avoid the re-entry of the age remains a significant challenge. Often data scanning same information each reporting period. is outsourced to external contractors, which is not only • Autocomplete fields can help speed up the process expensive but also exposes the system to security risks. by making suggestions when the declarant starts Electronic systems allow uploading and saving data typing in data. in a central data storage system to prevent loss of data. Data can and should be stored in a format that • The filer can select items from dropdown lists in- facilitates further analysis and any other processing stead of typing in information. needed. The process of transitioning to an electronic • Hints, examples, and explanations (definitions) system also allows for greater consistency and uniform can be embedded in the form and made easily application through new standardized forms and data accessible. requirements. 4  |  E-filing Asset Declarations: Benefits and Challenges StAR-asset-disclosure-report-06-print.indd 4 5/21/19 5:09 PM Electronic systems ensure higher quality of data. Other benefits for relevant agencies: Features such as built-in validations to prevent logical • Officers of the reviewing agency can easily and and arithmetic mistakes by declarants minimize data quickly find and retrieve electronic forms entry errors and simplify the future analysis of decla- rations. Drop-down menus and autocomplete function • An electronic system of submission facilitates the also facilitate higher data quality. In some systems, the creation of a register of filers, which can be used to validation of data entry can be carried out in real time ensure compliance with the obligation to disclose. by comparing data with external registries (e.g. real • An electronic system allows comparing a decla- estate, vehicles, taxes) that are integrated with the asset ration with the one previously filed and focusing declaration system. only on recent changes. An online form can be easily adjusted to accommo- date changes in the law/bylaws or to improve user ex- • Officers of the reviewing agency can use the elec- perience and interface based on the filers’ feedback and tronic system to search, filter, and sort declarations other input. The electronic system, therefore, provides and the data therein to select declarations that need a more flexible asset declaration form. further review or verification, etc. Digital tools can guarantee data integrity and • The reviewing agency can send questions to the prevent the altering or compromising of data. The declarant through the electronic system and receive system should be able to prove with certainty the authenticated (through digital signatures) replies, integrity of data, e.g. by signing the electronic docu- which may then be used in legal proceedings. ment with the digital signature of the declarant and Declarants may also submit explanations and re- counter-signing it with the digital signature (“stamp”) quested documents electronically during the analy- of the collecting agency. sis and verification procedure. Such communication Electronic systems can help better secure informa- will be securely stored in the system alongside the tion from unauthorized disclosure or loss. Data secu- asset declaration and can later be used in legal pro- rity should be built into the system’s architecture as a ceedings if needed. crucial element to guarantee protection, sustainability, and usability of data. Electronic systems also make it • Electronic systems can be used to send mass or in- easier to implement necessary procedures to ensure dividual alerts and warnings to the declarants to protection of personal data within the declarations, so inform them about upcoming or missed deadlines. that information is processed lawfully and in compli- • The electronic system can also be set up to auto- ance with other personal data protection principles and matically check the timely filing of declarations by rights of the declarants. This can be achieved by tracking declarants who have already registered in the system all processing operations with data in the system and and alert the enforcing agency about declarants who keeping detailed logs; such logs can be regularly audited fail to submit their declaration; the system will auto- to prevent abuse and unauthorized access. matically apply time stamps to the documents filed. Electronic submission systems also increase the ca- pacity of the asset declaration agencies to monitor and • An electronic system may also provide the structure report data on the disclosure system at the aggregate for case management serving as an environment level as well as at a sectoral or institutional level. in which the authorized personnel of the reviewing agency can access declarations, conduct their ver- 3. More effective review and enforcement ification, attach documents received or produced Electronic systems offer a range of benefits to anticor- during such verification, and track the entire pro- ruption and other enforcing agencies. When agency cess of analysis and verification until closure of the staff work with more accurate and complete data, the legal proceeding. time needed to review declarations decreases. Electronic forms standardize entry fields, which minimizes the re- 4. Increased transparency quired typing of information by declarants. This means and public accountability that the reviewing agency will have to spend much less Electronic systems open new possibilities for public time on verifying incomplete and unintended errors, transparency and accountability by allowing civil so- allowing staff to focus on allegations of intentional ciety organizations, the media, and other members of misrepresentation. the public to scrutinize the information submitted by E-filing Asset Declaration | 5 StAR-asset-disclosure-report-06-print.indd 5 5/21/19 5:09 PM declarants. Online publication of submitted data does • Using joint teams of IT, asset declaration, and not require any burdensome processing and can provide public sector reform experts to design the architec- open access of the public to data in the declarations. ture of the e-filing system can be key to successful Some of the information disclosed by filers cannot implementation. be made public due to personal data protections where • Planning and designing the electronic system the right to privacy and personal security outweighs should be based on a cost-benefit analysis. It the public interest in the disclosure. Electronic systems should start with identifying the ultimate objective make it easy to manage different access regimes, for ex- of the new system – is it preventing and detecting ample, by allowing full access to data in the declarations conflict of interest, unexplained wealth variations, to authorized personnel of the enforcing agencies and or both? The functionalities of the e-filing system limited access to the general public by aggregating or might be slightly different based on the objective. redacting certain data (e.g. ID numbers, dates of birth, As to the transition to an electronic system, the full address of properties). impetus may be an urgent need to address chal- An electronic system of asset and interest disclo- lenges related to the paper-based system that affect sure enables data collection and processing in a ma- the collecting agency and the declarants. Other chine-readable format. It makes it possible to publish times, it may be a desire for general improvement declarations in open data formats and reuse data. of the system to facilitate the submission process Machine-readable data can be used to better view the and provide for a larger number of declarants. information from asset and interest declarations, pro- In some countries, the main driver of the tran- vide better search and analysis capabilities, and allow sition could be the need to introduce an effective for integration with other data sources.5 procedure for asset declarations verification and increasing compliance. Challenges to Introducing Electronic Filing Systems • As with all new systems requiring investment in In order to take full advantage of the benefits offered by hardware and IT services, the development, launch, the electronic disclosure systems, it is important to an- and maintenance of the electronic disclosure system ticipate and address challenges that may emerge during will require funding. Resources need to be allocated the design and implementation of the new system. Such not only for the development of the software for challenges can include: submission of the declarations, but also for data storage, the training of filers, or providing call cen- • The legal framework might need amendments to ter support services especially when the system is allow for electronic submission. first launched. • The institution in charge of developing and launch- • The number of declarants captured by the elec- ing the new system may not have sufficient human tronic system and intensity of declarants’ work ses- resources and/or expertise to develop and main- sions in the system may be underestimated during tain the system or the capacity to process inquiries the planning stage; the new system should, there- from the declarants. This also includes the need for fore, be designed in a way that can scale well and resources to host and administer the system and adjust to accommodate a much larger number of ensure its security and stability. It may be possible electronic documents and sessions than originally to outsource some of these services until in-house needed at inception. capacity is developed. • The system should address the issue of data integ- • The development and launch of the new system rity and provide safeguards for data authenticity require careful planning and may need a phased that will withstand legal challenges. approach to ensure attainable deliverables and realistic schedule of implementation. Successful • Registration and authentication in the electronic transitions to electronic filing use lessons learned system should be carefully designed with the pos- from launching other e-governance services, in- sibility of using alternative methods in the early volve multiple stakeholders, and must budget for stages of operation (e.g. bankID, mobileID, na- ample preparation and testing time.6 tional digital IDs). This is especially important if the country does not already have a functioning 6  |  E-filing Asset Declarations: Benefits and Challenges StAR-asset-disclosure-report-06-print.indd 6 5/21/19 5:09 PM system of digital identification and authorization should be clear how long each declaration will be (e.g. a developed infrastructure of digital trust stored in the system and how long it will it be pub- services). There should also be a legal basis that licly available, what happens with the declarations allows using certain methods of authentication, of candidates for public offices who are not ulti- e.g. e-signatures. mately recruited (if such candidates are supposed to file a declaration when applying), what happens • Even when the law and infrastructure of digital trust with data of deceased declarants, etc. services are in place, it is necessary to decide who issues and pays for e-signatures to the filers (e.g. • If the system is not designed based on the open data only government service providers or commercial by default principle, it may be difficult and more entities too). resource intensive to introduce open data standards at later stages. It is easier to capture and process data • Awareness raising and training are important to from the beginning in the form that will allow data raise the level of compliance, ensure trust in the publication and reuse in a machine-readable format new system, and facilitate a smooth operation. Such in the future. awareness raising and training should cover declar- ants, anticorruption officers or other focal points • Considerations of personal data protection of the public institutions, and the general public. should be taken into account from the start of the electronic system development and its imple- • Regulations should clearly stipulate the rules for mentation to avoid legal challenges of violations the duration of storing electronic data entered in of the filers’ rights. the system and its publication. More specifically, it Endnotes 1. Rossi, Ivana M., Laura Pop, and Tammar Berger. 2017. “Getting the Full Picture on Public Officials: A How-To Guide for Effective Financial Disclosure.” Stolen Asset Recovery (StAR) Series. Washington, DC: World Bank. doi:10.1596/978-1-4648-0953-8. 2. StAR (Stolen Asset Recovery Initiative). 2012. “Public Office, Private Interests: Accountability through Income and Asset Disclosure.” Washington, DC: World Bank. doi: 10.1596/978-0-8213-9452-6. 3. “Getting the Full Picture on Public Officials: A How-To Guide for Effective Financial Disclosure.” StAR, 2017, cited above. 4. Idem, pages 61-62. 5. See also Western Balkan Recommendation on Disclosure of Finances and Interests by Public Officials: “H.1 As monitoring by the public at large is one of the most effective tools, income and asset declarations should be available online. Ideally, declarations submitted online are published in real time. A useful public database of declarations requires in particular electronic and free access, and data in searchable, machine-readable format.” 6. Getting the Full Picture on Public Officials: A How-To Guide for Effective Financial Disclosure, StAR, 2017, cited above, page 65. E-filing Asset Declaration | 7 StAR-asset-disclosure-report-06-print.indd 7 5/21/19 5:09 PM Country Examples 1. France in 2014: nearly 18 000 declarations, which is far more The current asset and interest disclosure system in than what the former Commission for financial trans- France is regulated by the 2013 law on Transparency parency of political life (the High Authority’s prede- in Public Life,1 which is administered by the High Au- cessor) had ever received during its existence. In 2017 thority for Transparency in Public Life. 10,622 declarations were received, mainly declarations The initial scope of the October 2013 Law covered of interest and activities (4097), declarations of assets approximately 10,000 public officials. It incrementally (4327), and end-of-mandate or end-of-mandate decla- expanded to reach about 15,800 public officials as of rations of assets (2198). January 1, 2018. These public officials must submit to Beyond the 15800 high-ranking officials whose dec- the High Authority, within two months of taking office laration obligations are managed by the High Authority, or beginning of their mandate, two declarations: a dec- there are other categories of officials who have to file, laration of assets and a declaration of interests. Public but whose declarations are managed under other insti- officials must also submit an end-of-term declaration tutional arrangements. For instance, there is a system of assets no later than two months after termination of interest disclosure for the members of the judiciary of their functions or before the end of term for elected carrying adjudicative functions, which is internal to officials.2 In between, they must update their declara- the judiciary. tion of assets in case of substantive change (inheritance, acquisition of a property, etc.). If there is no substantial Registration: In order to register in the electronic filing change in assets, the filers do not need to file a new system, filers need to use a mobile phone number and declaration. In case of a substantial modification of the a valid email address. Registration is validated through public official’s interests (new activities, change in the text message. Text message validation is also used when spouse or partner’s professional activity, substantial a new declaration is filed or when public officials try change in the share portfolios, etc.), the official must to access their confidential personal information. The update the declaration of interests. official can also choose to register using an official email In 2014, all declarations were received in paper for- address (gouv.fr, assemble-nationale.fr or senat.fr). mat only. Starting in March 2015, declarations submitted When the account is first created, after the valida- to the High Authority could either be sent by registered tion through text message or email, the official needs letter with a confirmation receipt or submitted in person to provide a personal identification document (ID or at the High Authority, which issued a receipt confirming passport) through the electronic application. The doc- the submission or through the online service ADEL. ument is verified by the High Authority upon receipt Since October 2016, all declarations are filed online. through the filing system. Filers may contact a dedicated hotline (by phone or email) if they have questions, and guidelines are pro- Security: The web-based application ADEL complies vided online for each step of the process. Beyond the with the French government’s “Référentiel Général de declarations, the High Authority recommends online Sécurité (The General Security Standard) in terms of submission of all documents accompanying the declara- data security. The technical security solution that was tion (e.g. blind trust, official notice of appointment etc.). designed for the ADEL system is based on an asymmet- A considerable number of declarations were received ric encryption. For a given declaration, there is one data 8  |  E-filing Asset Declarations: Benefits and Challenges StAR-asset-disclosure-report-06-print.indd 8 5/21/19 5:09 PM encryption key on the High Authority’s servers and one the mandate or functions, its content remains accessible data encryption key on the declarant’s side. for six months after that date. The declarations of in- terests of French members of the European Parliament, Submission system functionalities: Filers can access mayors of large cities, and regional heads are also avail- previous declarations if they were filed electronically. able online. This allows them to update information disclosed in the past. Checking compliance with disclosure obligations: In Filers are also able to send attachments and any addi- 2016, the High Authority designed and implemented a tional information and documents that may be needed software solution for the management of declarations to clarify a situation or a valuation that appears in the submitted online (Ulysse). It allows for simplified and declaration. Public officials receive guidance while filing stronger verification of the declarations. By automating the declarations to ensure that they include relevant several tasks, it simplifies the control of compliance with information in each field and to standardize the infor- the disclosure obligations. For example, this module mation collected. allows for the calculation of the submission deadlines The electronic filing system also provides access to for different public officials given their nomination and authorized staff of the High Authority to the declara- start of the term in office as well as indicates missed tions that are initiated and/or are partly drafted, but deadlines. Ulysse is hosted on the servers of the High not submitted by public officials. This can be helpful Authority and is accessible only to staff of the High Au- for declarants who, for technical reasons, may no longer thority that are involved in the verification of assets and be able to access a declaration that they had started to interests, with different levels of access corresponding fill in. to their scope of tasks. The High Authority also developed a media mon- Public access: One of the main objectives of the Oc- itoring software (ARTEMIS) to collect information tober 2013 Law was to foster transparency in public available in open sources on the assets and interests of life through the publication of declarations online. Ini- public officials falling under the High Authority’s juris- tially, declarations received by the High Authority were diction. The objective is to facilitate the High Authority’s in a paper format, which required the Authority to access to any public information that may be useful to scan and anonymize the data before publication on the ensure that the submitted declarations are complete High Authority website. The transition to electronic and accurate. ARTEMIS has been designed in relation filing made it possible to make the content of declara- to Ulysse, the declaration management tool. It scans tions publicly available in an open data format (xml) open sources daily based on the list of declarants and starting in 2017. The list of published statements is the criteria defined by the system administrator. The available on the High Authority website https://www. objective is to collect new publicly available information hatvp.fr/consulter-les-declarations/, but also on the on the declarants regularly without having to check all platform data.gouv.fr. All declarations are published news media and open sources manually. under open license. According to the High Authority, the transition to the Under the October 2013 Law on transparency in electronic filing system allowed to collect standardized public life, the content of the declarations of assets and data from the declarants, which enhanced the quality of declarations of interests of the Government and Par- data declared and also made it easier for filers to comply liament members should be made public within three with their obligations. The new electronic systems made months after the Authority receives the tax administra- it possible to automate certain control functions linked tion’s conclusions on the respective declarations. The to the input of the content of declarations and submis- published declarations remain online until the end of sion requirements. In addition, the electronic systems the official’s mandate or the termination of their func- offered new opportunities for the automation of internal tions. When the declaration is filed after termination of consistency control and change of wealth calculation. Endnotes Source: web-site of the High Authority for Transparency in Public Life (www.hatvp.fr/en). The case study also includes materials and feedback kindly provided by the High Authority to the authors of the paper. 1. Official Journal of the French Republic (JORF) no. 0238 of 12 October 2013, page 16829, available at https://www.legifrance.gouv.fr/content/.../8845/.../l_2013_907_ en_2013_10_13.pdf. 2. Members of Parliament must submit their end of term declaration of assets between 7 and 6 months prior to the end of the time in office. Local officials must submit their end of term declaration between 2 and 1 month prior to leaving office. Country Examples | 9 StAR-asset-disclosure-report-06-print.indd 9 5/21/19 5:09 PM Sections of the asset declaration form, including drop down menus 10  |  E-filing Asset Declarations: Benefits and Challenges StAR-asset-disclosure-report-06-print.indd 10 5/21/19 5:09 PM Sectios of the asset declaration form, including guide for filer Country Examples | 11 StAR-asset-disclosure-report-06-print.indd 11 5/21/19 5:09 PM 2. Ukraine office, prior to termination of office and one year after In 2015, Ukraine enacted the new Law on Corruption the termination of office and additional notifications of Prevention introducing a new system of interest and significant changes in assets. asset declarations for public officials to replace the pa- As of March 2019, the system included more than per-based system that was in place since 2011 with a 3,700,000 electronic documents (all publicly available fully electronic and web-based system for submission at https://public.nazk.gov.ua), including about 2,250,000 and publication of declarations. The new system aimed original declarations and about 390,000 corrected ver- to prevent conflict of interests of public officials, monitor sions of the declarations. variations of wealth and detect illicit enrichment, as well as increase transparency and accountability of public Registration: Declarants self-register in the on-line officials. The electronic system is run by the National system by accessing the NACP’s web-site using their Agency for Corruption Prevention (NACP). The new personal digital signature and providing their contacts law also extended the scope of information about assets, details (e-mail, mobile phone number). A personal dig- income, expenditures, liabilities and interests of declar- ital signature is required for each login in the system ants covered by the declaration form making it one of and submission of any document in the system. Digital the most comprehensive forms among countries with signatures are issued both by public entities (at no cost asset disclosure systems. to filers) and commercial entities (for a fee). Obtaining The new e-declarations system covers about 1 mil- the digital signature is the responsibility of the declarant. lion public sector employees in Ukraine. This includes There is no central register of declarants. Despite all civil servants, political officials, officials of law en- the fact that no external confirmation/verification of forcement agencies, judges, prosecutors, military ser- the registration is required, only a very small number vice personnel in administrative positions, members of of cases of registration in the system of persons who local councils at all levels, other local self-government were not declarants were reported. Upon completing officials and officials of public companies. A single the online registration, the declarant has a personal centralized system covers all branches of power and account in the system. all public authorities and entities. Declarants submit four types of declarations: prior to entering office (sub- Submission: After registering in the system, the declarant mitted by candidates for public office), annual while in can create drafts of the declaration and fill in data when Log-in page of the e-declarations system 12 | E-filing Asset Declarations: Benefits and Challenges StAR-asset-disclosure-report-06-print.indd 12 5/21/19 5:09 PM Declaration form convenient. The system also auto-saves data after a certain filer performs his public functions and is stored for five period of time. After filling in all sections of the declara- years afterwards. The final submitted declaration, how- tion, the declarant can review the completed version and ever, is stored indefinitely. There is a gap in regulating is warned about liability for false statements. After con- the storage of declarations filed by candidates for all firming that the data is accurate, the declarant has to use positions covered by the asset disclosure requirements their personal digital signature again to sign and submit who were ultimately not recruited. the declaration. Once submitted, the declarant is notified by e-mail with the submitted declaration attached. Public access: All declarations are automatically dis- closed on the public web-site of the NACP immediately Corrections: The declarant may file a corrected ver- after submission of the document in the system. sion within seven calendar days after submission of the Access to information on the public web-site of dec- declaration. After that, the declarant may submit a cor- larations is open and free, the identification of users or rected declaration only with NACP’s permission. Cor- pre-registration is not required. The public web-site rected versions are submitted and stored in the system provides filters and basic search functions to browse the as separate electronic documents, without replacement data. Public access is provided in html and pdf formats, or editing of the original versions. This ensures that as well as in machine-readable format (JSON) through there is no tampering with data after its submission a public API. in the system. Original and corrected declarations are Open data access to e-declarations has encouraged published on-line and have a time stamp that is visible civil society to develop analytical and watchdog tools to to the public. track disclosures, provide extended search and filtering of data, and connect data to other registers and data Storage of declarations: Information submitted by sources, e.g. company register and public procurement declarants is added in the system during the time the database.1 Country Examples | 13 StAR-asset-disclosure-report-06-print.indd 13 5/21/19 5:09 PM Electronic verification: One of the features of the Ukrainian • Simplified data entry by the declarant, user-friendly e-declarations system is the possibility to conduct auto- interface (hints, built-in guidelines). matic verification of the submitted electronic data. • Secure authentication protocol. The system automatically detects whether complete and valid data was entered in the form in accordance • Real time error prevention. with the detailed validation rules approved for each • Secure data storage (public-access web-site sepa- field; the system would not allow submission of the form rated from the main database). if some mandatory fields were empty or filled in with data in an incorrect format. • Submitted documents cannot be withdrawn or A separate module for the automated verification of changed in the system. data in the submitted declarations includes: • Each document displays the date and time of its 1. checking data for inconsistencies within one submission. declaration; • Built-in verification of data consistency. 2. comparing a declaration with the previous declara- • Use of dropdown lists, avoiding error-prone “open tions from the same declarant to look for deviations fields”. or other “red flags”; • E-mail notifications about registration in the sys- 3. comparing data from the declaration with external tem, deadlines, successful submission of the dec- data sources, such as public databases (registers of laration, etc. properties, companies, etc.). • Free read-only access to the public without prior This module was launched in January 2019. identification/authorization. The benefits of the new disclosure system: • Public API for open data access to declarations on • All declarations filed through the website of the the public website. NACP using one standard electronic form. Endnotes Source: NACP web-site (https://nazk.gov.ua/); research by the authors. 1. See, for instance, https://declarations.com.ua, https://pep.org.ua/en, https://interes.shtab.net, https://ring.org.ua. 14  |  E-filing Asset Declarations: Benefits and Challenges StAR-asset-disclosure-report-06-print.indd 14 5/21/19 5:09 PM 3. United States Integrity is a secure, web-based system through which Most Federal Government officials in the United individuals may file executive branch public disclosure States that have an obligation to file public financial reports, including new entrant, annual, periodic trans- disclosures do so through an electronic system. There action, and termination reports. Integrity was designed is no centralized submission system and each branch to help produce quality reports, enhance oversight, and of the government uses its own. A significant number promote transparency. In this regard, Integrity signifi- of Executive branch employees use a system called cantly enhances the filing, review, and program man- Integrity. In the legislative branch, the US Senate agement aspects of the executive branch public financial uses the “eFD” (Electronic Financial Disclosures) disclosure program in a number of ways. For example, system (https://efd.senate.gov), while the US House Integrity incorporates a combination of data-entry ta- uses - “Financial Disclosure: Online Reporting” bles and context dependent questions that help filers to (https://fd.house.gov). The Judicial Conference of identify all of their reportable financial interests and to the US Committee on Financial Disclosure operates disclose those interests correctly. As a result, Integrity “Financial Disclosure Online” (https://fd.uscourts. produces quality reports by helping filers more quickly, gov). Below is an overview of the Integrity system for easily, and completely report required information. the executive branch employees. Integrity also enhances oversight of the executive Under the Ethics in Government Act (EIGA), as branch ethics program by allowing OGE to monitor amended, the U.S. Office of Government Ethics (OGE) agencies’ progress in administering their individual is responsible for establishing and supervising a public financial disclosure programs. Further, Integrity en- financial disclosure program for the executive branch. ables agency ethics officials to assign, review, track, This public financial disclosure system has existed and manage reports electronically. Certified reports since 1978. In 2012, the Stop Trading on Congressional are maintained in Integrity for the statutorily required Knowledge Act, as amended, directed the President, time-period, at which time they are deleted in accor- acting through the Director of OGE, to develop an elec- dance with the Ethics in Government Act. tronic system for filing executive branch public financial OGE’s two primary objectives for Integrity have disclosure reports. As a result, OGE developed a system been to increase the accuracy of public financial dis- named Integrity to collect, manage, process, and store closure and to reduce the burden on filers. Toward financial disclosures. these ends, a cross-divisional team of OGE analysts Country Examples | 15 StAR-asset-disclosure-report-06-print.indd 15 5/21/19 5:09 PM Example of context-dependent questions Example of asset specific questions 16  |  E-filing Asset Declarations: Benefits and Challenges StAR-asset-disclosure-report-06-print.indd 16 5/21/19 5:09 PM Example of Pre-population Tool and attorneys with expertise in financial disclosure Pre-Population Tool: Integrity allows a filer to “pre-pop- developed the content for Integrity, and OGE worked ulate” a financial disclosure report with data from a closely with a team of user-experience professionals to prior new entrant or annual report. Integrity can also make the system user friendly. Throughout Integrity’s import data from any number of previously filed pe- development, OGE has collaborated with agency ethics riodic transaction reports (OGE Form 278-T), and officials, who provided input and tested the system the system specifically allows the filer to choose which extensively. periodic transaction reports to include or exclude. OGE also solicits continuous feedback on the oper- ations of Integrity and regularly considers suggestions Filer Wizards: Integrity improves accuracy by using for improvements to the system. OGE has established wizards to prompt filers to provide information they the Integrity Advisory Council, which is comprised might otherwise forget to report in an initial sub- of seasoned ethics officials, to ensure development mission. Aiming to reduce the burden on the filer, decisions are responsive to user needs. The Integrity however, OGE limited this targeted assistance to areas Advisory Council provides the Office of Government where filers make the most mistakes. In OGE’s expe- Ethics with recommendations for priorities for future rience, these areas involve financial interests related improvements and developments. to the outside employment and retirement plans of The system has been widely adopted throughout the filer and the filer’s spouse. Integrity’s wizards pose the executive branch, with over 100 agencies and more only those questions that are relevant to an individual than 10,000 filers registered during the first year. At filer. For example, if the filer lists a position outside the the beginning of January 2019, 139 agencies were pro- government, Integrity will walk the filer through the cessing financial disclosure reports in Integrity, with a wizard with questions focused on the types of income total of 17,622 individual filers registered in the sys- and assets associated with that position; if a filer has tem. Between January 1 and December 31, 2018, filers no outside positions, the system will skip the wizard. submitted more than 23,700 public financial disclosure Example: filer selects “university/college”, position reports. Currently Integrity is available for use by exec- – “professor or dean”, then the system will choose a utive-branch agencies without charge. specific path through the wizard and ask only the most Security is a key feature of Integrity. The system is relevant questions. “Wizard” is a dynamic system that housed in a secure government cloud and since its in- asks questions as needed; eliminates the risk that the ception has successfully undergone a full, independent filer will forget to supply some information later, as it security assessment annually (the latest one in 2018). happened with paper forms. Integrity’s security features include: 256-bit encryption, limited system access, role-based permissions, inde- Auto-Complete: OGE has programmed the names of pendent validation of security controls, and continuous over 13,000 financial interests into Integrity and plans to security monitoring. Integrity authenticates users by add additional names in the future. The asset name au- leveraging the auto-authentication services of MAX. tocomplete feature suggests possible matches for entries gov, an existing federal platform with over 300,000 us- as a filer is typing. Another auto-complete feature will ers. Integrity is a web-based application housed at the help filers with more complex holdings. For filers with U.S. Department of Agriculture’s National Information private investment funds that do not qualify as excepted Technology Center. investment funds, Integrity allows the filer to report the underlying holdings of the funds and associate them Key features for filers include: with the “parent” asset. The auto-complete feature will Country Examples | 17 StAR-asset-disclosure-report-06-print.indd 17 5/21/19 5:09 PM Example of Comparison Feature Example of Notifications Page suggest a list of possible parent assets by drawing from Key features for reviewers include: the names of assets that the filer has already entered. Comparison of Reports: Normally, a filer will “pre-pop- Comments and Endnotes: Filers may use this feature ulate” the report with information from a previous report to submit comments and questions to reviewers or add before adding, deleting, or revising entries. In that case, an detailed public endnotes that are incorporated into the agency ethics official assigned to review the report can use financial disclosure report to provide explanatory in- Integrity’s comparison tool to examine only items that have formation about their assets. changed since the previous report. This tool significantly reduces the workload of agency ethics officials and makes Easy Login: To log into Integrity, users enter their exist- their reviews more effective by highlighting items that ing MAX identity and password. At some agencies, filers have not previously been reviewed for conflicts of interest. can simply swipe their “smart” ID cards. Other agencies have entered into federated login arrangements with Public Annotations: A reviewer may use this feature to MAX.gov, which means that filers are automatically add notes on the face of the publicly releasable version logged into Integrity by virtue of having logged into of the OGE Form 278e or the OGE Form 278-T. These their agencies’ networks. notes are printed in a “Comments of Reviewing Offi- cials” section at the beginning of the report. Third-party access: Integrity has an option that enables the filer to give someone else (e.g., an accountant, fi- Comments: A reviewer may use this feature to instruct nancial planner, or spouse) access to his/her Integrity a filer to make corrections or supply additional infor- account so that the individual can assist with prepara- mation. By making a comment in-line, the reviewer can tion of the report. Third parties cannot sign the report, draw the filer’s attention directly to the item that needs which can only be signed by the filer. correction or additional information. 18  |  E-filing Asset Declarations: Benefits and Challenges StAR-asset-disclosure-report-06-print.indd 18 5/21/19 5:09 PM Documents: A reviewer or filer can upload documents of reports that agency has in Integrity, the number of related to the report (e.g., a job description or ethics reports requiring action, the number of reports due to counseling memo) that will remain associated with the the agency, as well as other management reports. report. Public access. The public access provisions of the Ethics Notices and Reminders: Integrity can help ethics offi- in Government Act of 1978 and the Stop Trading on cials manage their agency’s financial disclosure program Congressional Knowledge Act of 2012 permit mem- by sending a variety of notices and reminders to both bers of the public to inspect public reports or receive filers and reviewers. copies of these reports. The information from filed reports is not aggregated into searchable, sortable and Workflows: Integrity contains a variety of workflow downloadable databases. The reports of the President, options in order to tailor the review process to the Vice President and officials occupying levels I and II needs of individual agencies. The workflows govern the of the Executive Schedule are posted on-line and can processing sequence as a report progresses from initial be downloaded from OGE’s website, www.oge.gov.1 assignment to final certification. Reports of other high-level officials who are appointed by the President with Senate confirmation can be re- Management Reports: Integrity allows ethics officials and quested through an electronic form located on OGE’s program administrators to run a number of management website. Other public financial disclosure reports can status reports, including running data sets on the number be requested from the agency where the official files. Endnotes Source: OGE, Integrity User Guide (Ver. 2, 2018); OGE, Program Advisory, March 2015, available at https://bit.ly/2vFhkDs; OGE Annual Performance Report, Fiscal Year 2017, available at https://bit.ly/2HR3EKq; CY16 Annual Agency Ethics Program Questionnaire Results, July 2017, available at https://bit.ly/2HUvHGs; other materials of OGE web-site www.oge.gov. The case study also includes materials and feedback kindly provided by the OGE to the authors of the paper. 1. At the time of publishing the financial disclosures of the President, Vice President and officials occupying levels I and II of the Executive Schedule can be accessed at: https://extapps2.oge.gov/201/Presiden.nsf/President%20and%20Vice%20President%20Index https://extapps2.oge.gov/201/Presiden.nsf/PAS%20Index?OpenView Country Examples | 19 StAR-asset-disclosure-report-06-print.indd 19 5/21/19 5:09 PM StAR-asset-disclosure-report-06-print.indd 20 5/21/19 5:09 PM StAR-asset-disclosure-report-06-print.indd 21 5/21/19 5:09 PM StAR publications have been the knowledge products geared toward providing tools and good practices to practitioners and are the backbone of country engagement and capacity-building. Getting the Full Picture on Public Officials A How-To Guide for Effective Financial Disclosure Getting the Full Picture on Public Officials Public Office, Private Interests The Puppet Masters A How-To Guide for Accountability through Income and Asset Disclosure How the Corrupt Use Legal Structures to Effective Financial Disclosure Hide Stolen Assets and What to Do About It Emile van der Does de Willebois Ivana M. Rossi Emily M. Halter Laura Pop Robert A. Harrison Tammar Berger Ji Won Park J.C. Sharman A GOOD PRACTICES GUIDE FOR NON-CONVICTION BASED ASSET FORFEITURE Barriers to Asset Recovery Asset Recovery Handbook Theodore S. Greenberg On the Take An Analysis of the Key Barriers and A Guide for Practitioners Linda M. Samuel Criminalizing Illicit Enrichment to Wingate Grant Recommendations for Action Larissa Gray Fight Corruption Lindy Muzila Kevin M. Stephenson Jean-Pierre Brun Michelle Morales Larissa Gray Larissa Gray Marianne Mathias Ric Power Clive Scott Tammar Berger Jean-Pierre Brun Kevin M. Stephenson Gabriele Dunker Melissa Panjer All publications are available for free In recent years, revelations of grand corruption and the plunder of state assets have led to greater scrutiny of financial relationships with politically exposed persons (PEPs)—senior government officials and their family members and close associates. Notwithstanding the efforts by many Politically Exposed Persons download and in different languages: PREVENTIVE MEASURES FOR THE BANKING SECTOR star.worldbank.org financial institutions and regulatory authorities to prevent corrupt PEPs from entering and using the financial system to launder the proceeds of corruption, there has been an overall failure in the effective implementation of international standards on PEPs. Theodore S. Greenberg Few and Far Implementation of an effective PEP regime is a critical component in the prevention and detection Larissa Gray Politically Exposed Persons of transfers of proceeds of crime and, therefore, ultimately in the process of recovering them. The Hard Facts Politically onPreventive Exposed Persons: Stolen Asset Measures for Recovery the Banking Sector is designed to help banks Delphine Schantz Carolin Gardner Michael Latham and regulatory authorities address the risks posed by PEPs and prevent corrupt PEPs from using domestic and international financial systems to launder the proceeds of corruption. The book provides recommendations and good practices aimed at improving compliance with international Larissa Gray standards and increasing supervisory effectiveness. It is an important tool for individuals, Kjetil Hansen governments, financial and private sector companies, and international organizations involved in ‫ عوائق‬Public Disclosure Authorized Pranvera Recica-Kirkbride Linnea Mills developing and implementing standards aimed at fighting corruption and money laundering, and trying to recover stolen assets and the proceeds of corruption. Personas Expuestas Politicamente ‫ مليار دوالر اأمريكي كل عللام من خللال الر�شوة‬40-20 ‫البلدان النامية مبلغا يللراوح بني‬ ‫ مليار دوالر‬600-300 ‫ وهكذا اختفى نحو‬.‫ وغريها من ممار�شات الف�شاد‬،‫تفقد واختا�س االأموال‬ Greenberg, Gray, Schantz, Gardner, Latham ‫ ويعتقد اأن معظم هذه االأموال املنهوبة من البلدان النامية يتم‬.‫على مدى خم�شة ع�شر عاما‬ Medidas Preventivas Para el sector Bancario ‫ مليارات دوالر‬5 ‫ واملوؤ�شف اأنه مل يعد منها �شوى‬.‫حتويلها اإىل اخلارج واإخفاوؤها يف واليات ق�شائية اأجنبية‬ Authorized ‫عوائـق ا�سرتداد الأموال‬ ‫ا�سرتداد ال‬ StAR—the Stolen Asset Recovery Initiative—is a partnership between the World Bank Group Theodore S. Greenberg Les Profiteurs !‫على مدى اخلم�س ع�شرة �شنة املا�شية‬ ‫وهذه الفجوة الهائلة يف اال�شرداد الفعلي لاأموال املنهوبة ت�شري اإىل وجود عوائق مهمة تعرقل ا�شرداد‬ Public Disclosure Larissa Gray and the United Nations Office on Drugs and Crime that supports international efforts to end safe Delphine Schantz ‫حتليل للعوائق الرئي�سية وتو�سيات للعمل‬ Incriminer ‫) كتاب «عوائق‬StAR( l’enrichissement illicite ‫ اأ�شدرت مبادرة ا�شرداد االأموال املنهوبة‬،‫الفجوة‬ ‫ وبغية معاجلة هذه‬.‫تلك االأموال‬ .‫ وهو حتليل دقيق لهذه العقبات واأثرها ال�شلبي‬،»‫ا�شرداد االأموال‬ ‫املتحدة‬combattre pour la corruption ‫أموال‬ Carolin Gardner Michael Latham havens for corrupt funds. StAR is working with both developing countries and financial centers to ‫ ا�ستيفين�سون‬.‫كيفني اإم‬ ‫ وتوفر اتفاقية االأمم‬.‫وا�شردادها‬ ‫ويعترب التعاون الدويل اأمرا حا�شما لتعقب االأموال املنهوبة‬ ‫لري�سا غراي‬ ‫ملكافحة الف�شاد برناجما رئي�شيا لتعزيز هذا العمل اجلماعي– كما ت�شهد به االلتزامات التي تعهدت بها‬ prevent laundering of the proceeds of corruption and to facilitate the more systematic and timely ‫ريك باور‬ Lindy‫ميكن‬ ‫ والقطاع اخلا�س– لكنها لي�شت بل�شما �شافيا؛ الأن كثريا من العوائق ال‬،‫ واملجتمع املدين‬،‫احلكومات‬ Muzila Public Disclosure Authorized ‫جان–بيري برون‬ Michelle Morales .‫التغلب عليها من خال االتفاقية‬ return of stolen assets. ‫ ال�سحات من�سور‬:‫ترجمة‬ ‫غابرييل دنكر‬ Marianne Mathias ‫توجيه �شناع‬ ‫ تهدف هذه الدرا�شة اإىل‬،‫وا�شتنادا اإىل خربة املمار�شني الفنية من خال التجارب العملية‬ ‫ كمــــال ال�ســـــيد‬:‫مراجعة‬ Tammar Berger ‫ميلي�سا باجنري‬ ‫ال�شيا�شات وتعزيز التو�شيات العملية الرامية مل�شاعدة الواليات الق�شائية يف ا�شتنباط �شيا�شات ناجعة‬ ‫ واملوؤ�ش�شات‬،‫ واملنظمات الدولية‬،‫ وتلعب جمموعة الع�شرين‬.‫ال�شرداد االأموال املنهوبة ب�شورة ب�شيطة‬ .‫ واملجتمع املدين دورا رئي�شيا يف �شمان التقدم امللمو�س يف تنفيذ هذه التو�شيات‬،‫ والوكاالت االإمنائية‬،‫املالية‬ ‫ا�ستيفين�سون • غراي • باور • برون • دنكر • باجنري‬ Delivered by The World Bank e-library to: The World Bank Public Disclosure Authorized 978-0-8213-8249-3 IP : 192.86.100.35 Tue, 11 May 2010 22:09:59 ‫) هي �شراكة بني جمموعة البنك الدويل ومكتب االأمم املتحدة املعني باملخدرات‬StAR( ‫مبادرة ا�شرداد االأموال املنهوبة‬ ‫ وتعمل املبادرة مع البلدان‬.‫ وترمي اإىل دعم اجلهود الدولية ملنع االأموال الفا�شدة من احل�شول على ماذ اآمن‬.‫واجلرمية‬ .‫النامية واملراكز املالية ملنع غ�شل ح�شيلة اأعمال الف�شاد ولت�شهيل رد االأموال املنهوبة على نحو اأ�شرع واأكرث منهجية‬ ‫مركز األهـرام‬ ‫للنشــر‬ SKU 18249 (c) The International Bank for Reconstruction and Development / The World Bank StAR-asset-disclosure-report-06-print.indd 22 5/21/19 5:09 PM