Search through the full set of commitment data, accurate according to our chapters’ research up to spring 2018. You can download the full dataset yourself, or search the commitments below by:
You can see the full project methodology here.
|Central Register||19/11/2018||Australia is committed to exploring, via public consultation, options for a beneficial ownership register for companies.||Australia||Overdue||June 2018 update: Treasury has considered submissions to the public consultation but the Government is still considering what actions to take to increase the transparency of beneficial ownership. See Senator McAllister and Mr Sterland's exchange on 22/05/2018.||Beneficial ownership||Open Government Partnership - Australia's Profile - commitment 1.2 Finance and Public Administration Legislation Committee 22/05/2018 Submissions to the public consultation|
|Public Contracting||07/11/2018||We will take steps to ensure transparency of the beneficial ownership of all companies involved in public contracting.||Russia||Underway||
October 2018 update: President's Order 'National plan on anticorruption 2018-2020' proposes to forbid participation in public procurement for companies which are controlled by offshore entities and persons.
|Beneficial ownership||The President of the Russian Federation approved the National Anti-Corruption Plan for 2018 - 2020|
|Open Contracting in Health||23/10/2018||Recognizing the financial, economic and developmental importance of health and pharmaceutical procurement, we commit to explore the implementation open contracting in this sector, according to our national legislation, and with the support from international partners in implementing this commitment.||Mexico||Underway||
October 2018 update: The Ministry of Finance and Public Credit (Secretaría de Hacienda y Crédito Público) is in conversation with the public health sector, which have different procurement systems (IMSS and ISSSTE) to publish their contracting processes using the Open Contracting Data Standard in its Mexican version.
June 2018 update: No change.
July 2017 update: The public administration recently published contracting processes from the general public administration office. Even though, contracting processes from the health sector are not included (IMSS and ISSSTE), there is a note in the platform which makes reference to works being done in order to publish this data but because these institutions have different payment systems, there is an added difficulty to the publishing of these contracting processes.
|Public procurement||Note from the Mexican Government as to why this data is not available yet. Open contracting database|
|Open Contracting||23/10/2018||We will propose reforms to the federal regulatory framework related to public procurement in responsibility of the executive in order to promote the principles of Open Contracting to include the planning and execution stages.||Mexico||Underway||
October 2018 update: No change since 2017
Along with the World Bank, Mexico developed an adaptation for the Open Contracting Data Standard for it to work with the national procurement system, the adaptation considers through extensions specific aspects of the Mexican public procurement legislation. Currently, the Federal Public Administration is developing a platform in which all contracts are published using the Open Contracting Data Standard. The Standard includes information from all the contracting cycle, starting in the planning stage and ending in its implementation.
|Public procurement||Agreement establishing the inclusion of Mexican public procurment information to the CompraNet portal.|
|Data Literacy||23/10/2018||We commit to promote a data-driven culture in the public sector.||Mexico||Ongoing||
October 2018 update: The Technical Secretariat (Secretaría Técnica, SESNA) of the National Anticorruption System (Sistema Nacional Anticorrupción, SNA) has the responsability of the creation of the National Digital Platform and promotes the data driven culture in the public sector.
June 2018 update: No change.
July 2017 update: The creation of the innovation hub is one of the efforts to promote data driven culture in the public sector
|Open data||FEDERAL Law on transparency and access to public information OECD 'Open Government Data in Mexico' Report 2018 SFP and SESNA install permanent table for the construction of the National digital platform|
|Asset Recovery Guidelines||23/10/2018||We commit to develop internationally-endorsed guidelines for the transparent and accountable administration of returned assets||Mexico||Ongoing||October 2018 update: No change.||Asset recovery||Mexico attends 'The Addis Ababa Action Agenda' which encourages the international community to develop good practices on asset return.|
|Transparency and Integrity||23/10/2018||New Zealand will continue and intensify efforts to develop procurement capability, including initiatives that safeguard integrity in the procurement process.||New Zealand||Ongoing||
October 2018 update: New Zealand is also reviewing its policy framework and guidance to strengthen the government’s expectations for ethical behaviour and for suppliers not to engage in any form of corruption. Economic Development who under the previous government regarded procurement as a low priority. Recent events, such as the Auckland Transport Case, has brought procurement practice into focus.
June 2018 update: Government tenders are advertised online. New Zealand has also established a Procurement Capability Index, which is a tool designed to assist government agencies to self-assess procurement performance against a wide range of measures, including governance, accountability and good procurement practice measures. From mid to late 2017, all agencies covered by the Government Rules of Sourcing will be required to complete the Procurement Capability Index. New Zealand Government Procurement will report the findings to Ministers. TINZ does not consider that the monitoring of procurement implementation is strong enough and is working to raise this and find ways of improving it.
|Public procurement||Government tenders are advertised online|
|International Anti-Corruption Coordination Centre||23/10/2018||New Zealand will support the proposal to establish an International Anti-Corruption Law Enforcement Coordination Centre (‘IACCC’) by nominating a representative to the IACCC.||New Zealand||Complete||
October 2018 update: New Zealand has nominated representatives to the Governance Board of the IACCC and provided a London based resource to the IACCC. This person is employed by the NZ Serious Fraud Office who liaises regularly to facilitate the provision of NZ based information relevant to IACCC work. New Zealand Police have increased the capacity of its FIU so that, amongst other things, it is better equipped to work closely with relevant international and national organisations to support countries to keep out the proceeds/ activities of grand corruption.
June 2018 update: New Zealand Police have increased the capacity of its FIU so that, amongst other things, it is better equipped to work closely with relevant international and national organisations to support countries to keep out the proceeds/ activities of grand corruption.
|Law enforcement||New Zealand has nominated representatives to the Governance Board of the IACCC|
|Debarment Database||23/10/2018||New Zealand will explore establishing an accessible and central database of companies with final convictions for bribery and corruption offences, and ways of sharing information on corrupt bidders across borders.||New Zealand||Complete||
October 2018 update: Agencies have not provided formal advice on centralising this information into an accessible database. However, officials’ preliminary exploration suggests that there is likely to be little benefit in establishing such a database. New Zealand has not convicted a company of bribery of corruption and, as such, there is no information for New Zealand to put in such a register at present. Overseas countries and civil society may, therefore, be better placed to establish registers in relation to overseas convictions that could then be shared with New Zealand. "We have given consideration to this issue, and the provisional view is that it is not a tangible benefit in proceeding with it at this stage. Given the commitment is to “explore”, not to implement, our view is that this commitment could arguably be assessed as having been completed."
June 2018: It is unclear whether progress has been made to explore this initiative as the action taken refers to existing information initiatives on websites. There does not appear to be any concrete action to explore the possibility of a central database.
|Public procurement||Some relevant information is already available on the Serious Fraud Office website New Zealand Companies Office Register|
|Access to International Law Enforcement||23/10/2018||New Zealand will also continue to implement bilateral arrangements that will ensure law enforcement in one partner country has full and effective access to the beneficial ownership information of companies incorporated in the other partner country.||New Zealand||Underway||
October 2018 update: Limited progress has been made since the communiqué on measures to obtain beneficial ownership (BO) information. The company registry holds basic information but is not required to obtain BO information and this measure is not effective therefore. The measures for foreign trusts lack transparency and do not cover domestic trusts. Property can be purchased through nominees, in this way hiding beneficial owners, both overseas and local residents.
June 2018 update: The Taxation (Business Tax, Exchange of Information, and Remedial Matters) Bill, which followed the Government Inquiry into Foreign Trust Disclosure Rules, received Royal Assent on 21 February 2017. The Bill tightens New Zealand’s foreign trust disclosure rules, including for beneficiaries of fixed trusts. The amendments also allow Inland Revenue to share information about foreign trusts for law enforcement purposes with the Department of Internal Affairs and the Police. Inland Revenue has proceeded to implement the legislation, especially the registration requirement for foreign trusts. The requirement for annual returns will commence later this year. New Zealand law enforcement agencies can receive and provide information through various bilateral arrangements (such as tax treaties), multilateral arrangements (e.g. the Egmont Group), and through formal mutual legal assistance arrangements.
|Beneficial ownership||The Companies Act 1993 and Limited Partnerships Act 2008|
|Public Register||23/10/2018||Nigeria is committed to establishing a public central register of company beneficial ownership information. (The President of Nigeria has presented a draft Money Laundering Prevention and Prohibition Bill to the National Assembly in February, 2016. This Bill has defined Beneficial Ownership in line with FATF standards.)||Nigeria||Inactive||
October 2018 update: Despite rhetoric assuring the governmental commitment, there is no tangible action towards the establishment of the central register.
June 2018 update: The Senate of the Federal Republic of Nigeria passed the Companies and Allied Matters (Repeal and Re-enactment) Bill 2018 on Tuesday, May 15, 2018 with Beneficial Ownership as one of the key provisions around ease of doing business in Nigeria. These provisions in this legislative framework will mandate the disclosure of beneficial interests in a company’s shares and prescribe punitive measures for failing to disclose such interests. In this regard, where a person holds interests on behalf of another in a nominal capacity in a company, both parties (the owner and the nominal holder) are required to disclose the beneficial interests to the company.
|Beneficial ownership||The Repeal and Re-Enactment of The Companies and Allied Matters Act Doing Business Provisions in the Companies and Allied Matters (Repeal and Re - enactment) Bill 2018|
|Property||23/10/2018||Nigeria will establish a transparent central register of foreign companies bidding on public contracts and buying property.||Nigeria||Ongoing||
October 2018 update: The reviewed version of the CAMA mandates that this register shall be established, though no specific structure on how this will be managed, there is also no guarantee that this legal provision will be granted a speedy consideration. The most recent development on this commitment is the Corporate Affairs Commission issuance of a circular for all entities to disclose the beneficial owners in their annual report starting from the 2017 annual report. The reviewed Corporate and Allied Matters Act (CAMA) was passed by the Senate, we are waiting for the concurrence of the lower chamber before it goes for the presidential accent. The Corporate and allied Commission has issued a circular for the beneficial ownership disclosure for all entities to the Federal Executive Council which has been adopted.
June 2018 update: The most recent development on this commitment is the Corporate Affairs Commission issuance of a circular for all entities to disclose the beneficial owners in their annual report starting from the 2017 annual report.
|Beneficial ownership||NEITI unveils Nigeria’s Open Government Partnership COMPANIES AND ALLIED MATTERS ACT, 2017|
|Property||23/10/2018||We are taking steps to ensure transparency of the ownership and control of all companies involved in property purchase and public contracting. Nigeria is already collating this information through the Extractive Industry Initiative process and would extend it to other sectors.||Nigeria||Ongoing||
October 2018 update: The Corporate affairs commission has reviewed the entire Corporate and Allied Matters Act (CAMA) with a provision to incorporate not only the oil and gas sector in beneficial ownership disclosure but also all public and private sector players. This bill has been submitted to the legal drafting committee under the office of the attorney general of the federation in August 2017. However, despite the road map for establishing the beneficial ownership disclosure in the oil and gas sector as established by NEITI, there is no clear responsibility on who should establish the roadmap and implement this in other sectors.
June 2018 update: The Bureau of Public Procurement (BPP), has concluded plans to launch a citizen engagement portal that will feed interested persons with updates on government-approved projects. We are yet to see concrete results.
|Beneficial ownership||COMPANIES AND ALLIED MATTERS ACT, 2017|
|Open Contracting in Health||23/10/2018||We will apply the Open Contracting Data Standard to the following major projects – (ii) Building of Health Centres and Improvement of Health Services;||Nigeria||Inactive||
October 2018 update: The Bureau for Public Procurement has developed the Nigerian Open Contracting Portal (NOCOPO) and preparing to carry put a Pilot. No clarity on infrastructure in health sector contracting has been achieved, yet.
June 2018 update: There has been no development on the Open Data Contracting in building health centres.
|Public procurement||Federal Govt. urged to comply with open contracting data standards Esp. in the Health sector. Bureau of Public Procurement|
|Open Contracting Data Standard||23/10/2018||We will work towards full implementation of the principles of the Open Contracting Data Standard, focusing on major projects as an early priority. We will apply the Open Contracting Data Standard to the following major projects – (i) Development of Refineries in the oil Sector; (ii) Building of Health Centres and Improvement of Health Services; (iii) Building of Roads and other Infrastructures; (iv) Building of Schools and Improving Transparency in the Management of Education Funds and (v) Investment in the Power Sector.||Nigeria||Ongoing||
October 2018 update: The bureau of public procurement has established an e-procurement department with a dedicated staff, this department handles all procurement data and accessible ON REQUEST through their website, perhaps this has not gone beyond the pilot stage which was done with the Universal Basic Education Commission and other five ministries . The Nigeria Open Contracting Portal (NOCOPO) has been launched, this platform opens up public procurement in Nigeria for increased disclosure of procurement information to all stakeholders with a view to ensuring improved transparency and competition, prevent corruption, enhance active citizen participation towards achieving better service delivery and improved ease of doing business in Nigeria.
June 2018 update: Governmental agencies are urged to follow Open Contracting Data Standards but there is no evidence that they do. http://www.budeshi.ng/home/data collects data on open contracts. While between 2016-17 3934 contracts were monitored, there are no entries for 2017.
|Public procurement||Open Contracts Data Portal Announcement of the e-procurement system|
|Legislation||23/10/2018||We commit to the strengthening of our asset recovery legislation, including through non-conviction based confiscation powers and the introduction of unexplained wealth orders||Nigeria||Underway||
October 2018 update: The proceeds of crime bill 2014 passed the second reading in the senate on Wednesday May 17 2017 and has been referred to the committee on judiciary, human rights and legal matters. The bill in its current form stipulates crucial legal and institutional arrangements for managing asset recovery in Nigeria, and employing the non-conviction based asset forfeiture approach. The judiciary complains about operational difficulties and lack of training in the application of the legal framework
June 2018 update: Crucial Proceeds of Crime Bill 2014 has not been passed into Law despite repeated assurances of political commitment. Unexplained Wealth Order is not being discussed at all. Non-conviction based approaches are present in the legal framework and are occasionally used despite the complains from judges that the legislative provision is not clear.
|Asset recovery||Proceeds of Crime Bill factsheet Proceeds of Crime Bill passed|
|Automatic Exchange of Information||23/10/2018||We commit to joining the pilot initiative for automatic exchange of beneficial information.||Nigeria||Inactive||
October 2018 update: Nigeria has signed agreements with a number of nations, which provide for the Automatic Exchange of Information (AEI). These agreements allow the exchange of information between tax authorities of different countries and about financial accounts and investments to help stop tax evasion. Countries who are party to this agreement include Switzerland, Panama, the Bahamas and other tax havens.There is no proof that this collaboration would result in greater clarity on the beneficial ownership in key sectors on Nigerian economy. The continued suspension of Nigeria from the EGMONT group makes sharing of sensitive legal and financial data with international partners difficult.
|Beneficial ownership||THE NIGERIAN VOLUNTARY ASSET AND INCOME DECLARATION SCHEME (VAIDS) Automatic Exchange of Information Implementation Report 2017 (page 7)|
|International Anti-Corruption Coordination Centre||23/10/2018||We support the establishment of an International Anti-Corruption Coordination Centre to be managed by National Crimes Agency, UK. We will work with NCA in promoting this centre in the African region.||Nigeria||Ongoing||
October 2018 update: The African Union leaders resolved at their 31st summit which held on the 6th of July 2018 to establish the African peer Review Mechanism and the Advisory Board on Corruption. It remains to be seen if tangible policy action follows.
June 2018 update: There are number of exchanges with law enforcement authorities in UK, USA, UEA, etc. However, no discussion is underway to set up the International Anti-corruption Centre. Nigeria has still been suspended from the Egmont group and in September 2018 the Egmont group will decide if Nigeria will be expelled indefinitely.
|Law enforcement||Summary of the key decisions and declarations of the 31st African Union Summit|
|Asset Recovery Guidelines||23/10/2018||We commit to developing internationally endorsed guidelines for the transparent and accountable management of returned stolen assets.||Nigeria||Ongoing||
October 2018 update: The signing of the mutual legal assistance in criminal matters into law by the President of the Federal Republic of Nigeria on the 24th of August 2017 is a step in the right direction to actualising this commitment. This piece of legislation gives Nigerian government access to identify assets in different jurisdictions. There are recommendations by interest parties (local and international) in this regard, but have not been adopted by the Nigerian Government. The Presidential Committee has audit all recovered assets by governmental organisations and submitted to the president. Details of all recovered assets are not made public. Key legal provision Proceeds of Crime Act has not been passed, yet.
June 2018 update: The Presidential Advisory Committee Against Corruption (PACAC) has published a number of guidelines for anti-corruption agencies and judiciary on how to conduct final and interim forfeiture of assets. Crucially, guidelines on non-conviction based forfeitures have been also published. However, the PACAC is only an advisory committee with no authority to implement the guidelines. There has been a sharp increase in the volume of seized assets reported by the Economic Financial Crime Commission (EFCC). There is however no independent review on the management of these forfeited assets.
|Asset recovery||EFCC recovers assets. Nigeria participates in the Addis Ababa Action Agenda Buhari signs 9 agreements with UAE to strengthen FG’s anti-corruption campaign|
|Access to International Law Enforcement||23/10/2018||We are committed to implementing bilateral arrangements that will ensure law enforcement in one partner country has full and effective access to the beneficial ownership information of companies incorporated in the other partner country.||Nigeria||Ongoing||
October 2018 update: Nigeria's signing on to the United Nations Convention against corruption (UNCAC) is a step at creating an enabling environment for exchange of information on stolen assets. The signing of the mutual legal assistance in criminal matters into law by the President of the Federal Republic of Nigeria on the 24th of August 2017 is a step in the right direction to actualising this commitment. Volume of recovered assets from foreign jurisdictions has increased according to governmental sources. No independent audit of recovered assets has been conducted except 321 million USD of the Abacha loot repatriated from Switzerland.
June 2018 update: Nigeria's signing on to the United Nations Convention against corruption (UNCAC) is a step at creating an enabling environment for exchange of information on stolen assets. During the global forum on asset recovery in December 2017, Nigeria was also a focus for asset recovery efforts.
|Beneficial ownership||The Global Forum on Asset Recover: Assistance for Combatting Corruption in Nigeria, Sri Lanka, Tunisia, and Ukraine GLOBAL FORUM ON ASSET RECOVERY COMMUNIQUE Mutual Legal Assistance on Criminal Matters|
|Compensation||23/10/2018||We will engage in the development of common principles governing the payment of compensation to the countries affected, to ensure that such payments are made safely, fairly and in a transparent manner.||Switzerland||Ongoing||No change since 2017||Asset recovery||Report on the meeting of the Open-ended Intergovernmental Working Group on Asset Recovery held in Vienna on 25 and 26 August 2016|
|Asset Recovery Guidelines||23/10/2018||We commit to engaging in the development of internationally endorsed guidelines for the transparent and accountable management of returned stolen assets.||Switzerland||Complete||With a view to developing good practices on asset return, Switzerland co-organized an international expert meeting (Addis Ababa, February 2017) on the management and disposal of recovered and returned stolen assets, including in support of sustainable development.||Asset recovery||Switzerland co-organises an international expert meeting|
|International Anti-Corruption Coordination Centre||23/10/2018||Kenya supports the setting up of international mechanisms, to facilitate better coordination of anti-corruption law enforcement efforts and welcomes the establishment of an International Anti-Corruption Law Enforcement Coordination Centre and will work closely and cooperate with it and relevant international organizations.||Kenya||Inactive||No update on the IACCC.||Law enforcement||International Anti-Corruption Centre|
|International Anti-Corruption Coordination Centre||23/10/2018||Kenya offers to host the African Anti-Corruption Law Enforcement Coordination Centre.||Kenya||Inactive||No updates on the IACCC.||Law enforcement||International Anti-Corruption Coordination centre|
|Debarment Database||23/10/2018||Kenya commits to establishing accessible central databases of companies and individuals convicted of bribery and corrupt practices and to exploring ways of sharing information on corrupt bidders across borders.||Kenya||Inactive||Public procurement||Open Government Partnership Country profile- commitment 6- Create transparent public procurement process, public oversight of expenditure and ensure value-for-money towards citizen priorities|
|Public Register||23/10/2018||Kenya will take measures in line with her new Companies regulatory framework to establish public central registers of company beneficial ownership information.||Kenya||Ongoing||October 2018 update: Beneficial Ownership regulations have been developed and subjected to validation with various stakeholders||Beneficial ownership||Open Government Partnership Commitment 5 tracker|
|Accountable Repatriation||23/10/2018||Kenya commits to strengthening her asset recovery legislation and to strengthening capacities to undertake civil assets recovery. Kenya supports the development of internationally-endorsed guidelines for the transparent and accountable management of returned stolen assets.||Kenya||Ongoing||October 2018 update: Kenya has recently signed bilateral agreements with Jersey ,Switzerland and the UK to boost the recovery and repatriation of stolen funds.||Asset recovery||STATEMENT FROM THE OFFICE OF THE ATTORNEY GENERAL AND DEPARTMENT OF JUSTICE ON THE SIGNING CEREMONY OF MEMORANDUM OF UNDERSTANDING BETWEEN SWISS FEDERAL COUNCIL AND GOVERNMENT OF KENYA ON MUTUAL LEGAL ASSISTANCE IN CRIMINAL MATTERS Kenya signs bilateral agreement on repatriation of stolen funds|
|Access to International Law Enforcement||23/10/2018||Kenya commits to ensuring that international and domestic law enforcement agencies have full and effective access to beneficial ownership information for companies and other legal entities registered within their jurisdiction.||Kenya||Ongoing||October 2018 update: The drafting of the regulations has opened up a discussion regarding who gets to access the information in the database - stakeholder discussions.||Beneficial ownership||The Companies Amendment Act 2017|
|Access to Domestic Law Enforcement||23/10/2018||Ensuring that law enforcement agencies have full and effective access to beneficial ownership informationfor companies and other legal entities registered within their jurisdiction.||Afghanistan||Ongoing||June 2018 update: The efforts to introduce beneficial ownership legislation is ongoing in Afghanistan although the government has not been able to prepare and adopt any specific law or regulation on it. The High Economic Council approved the proposal to introduce beneficial ownership legislation and the subsequent meeting was chaired by Second Vice President to discuss the preparation of any such regulation. https://bit.ly/2HgSxqA In addition, discussions on undergoing in the Ministry of Mines and Petroleum to introduce an article on beneficial ownership and Political Exposed Persons in the new mining law. http://mom.gov.af/fa/news/336317||Beneficial ownership||High Economic Council approve the proposal to introduce beneficial ownership legislation. Ministry of Mines and Petroleum discuss introducing an article on beneficial ownership.|
|Open Data Charter||23/10/2018||We will implement the principles of the Open Data Charter.||Russia||Abandoned||
October 2018 update: Russia has been excluded from G8 and therefore is no more bounded by Open Data Charter.
|Open data||Russia no longer in the G8|
|Accountable Repatriation||23/10/2018||We will extend the use of international cooperation mechanisms for detection, seizure and return of corrupt assets from foreign jurisdictions.||Russia||No data||Asset recovery|
|Accountable Repatriation||23/10/2018||We will ensure availability of national competent authority for detection, seizure and return of corrupt assets from foreign jurisdictions.||Russia||No data||Asset recovery|
|Access to International Law Enforcement||23/10/2018||We commit to implement bilateral arrangements that will ensure law enforcement and financial intelligence units in one partner country has full and effective access to the beneficial ownership information of companies incorporated in the other partner country.||Russia||Ongoing||
October 2018 update: Federal tax service continues to exclude countries from its blacklist as making agreements to exchange tax info
|Beneficial ownership||Federal tax service continues to exclude countries from its blacklist as making agreements to exchange tax info|
|Access to Domestic Law Enforcement||23/10/2018||We commit to ensuring that national law enforcement agencies and financial intelligence unit have full and effective access to beneficial ownership information for companies and other legal entities registered within their jurisdiction.||Russia||No data||Beneficial ownership|
|Protecting Whistleblowers||23/10/2018||We commit to provide adequate protection to those who report corruption by strictly applying the ‘Act on anti-corruption and the Establishment and Operation of the Anti-Corruption and Civil Rights Commission’ and the ‘Act on the Protection of Public Interest Whistleblowers’.||South Korea||Ongoing||
October 2018 update: ACRC will promulgate the revised Act on the protection of Public interest whistleblowers on April 17. Which introduced a new provision of representative reporting by lawyers. Public interest reporters will become able to submit documents, or make a statement of opinion as well as file a report through lawyers,thereby strengthening the protection of confidentiality of the public interest reporters.
June 2018 update: No change.
July 2017 update: The ACRC provides protection and financial rewards for the persons who report corruption or violation of the public interest including public health and safety, the environment, consumer interests and fair competition under the Act on Anti-Corruption and the Establishment and Operation of the ACRC and the Act on the Protection of Public Interest Whistleblowers. Those who report foreign bribery are also protected under the latter Act. Between March 2008 and March 2017, the ACRC received a total of 28,982 reports of corruption, handled 168 cases of requests for the protection of whistleblowers, and provided a total of KRW 9.8 billion (about USD 9 million) financial rewards for whistleblowers in 314 cases. Between September 2011, when the new whistleblower Act was implemented, and March 2017, the ACRC received a total of 21,844 reports of public interest violations, handled 87 cases of requests for the protection of whistleblowers, and provided a total of KRW 4.2 billion (about USD 4 million) financial rewards for whistleblowers in 5,355 cases. The ACRC is currently seeking to amend the ACRC Act to expand protection for whistleblowers. The amendment bill is being reviewed by the Ministry of Legislation as of May 2017.
|Whistleblower/civil society space protection||ACRC Offers KRW 1.73 Billion in Compensation for Reporting Corruption or Public Interest Violation Representative reporting by lawyers introduced to protect whistle-blowers’ identities|
|Transparency and Integrity||23/10/2018||We, with the Online E-Procurement System we have developed, commit to ensure transparency in public procurement.||South Korea||Ongoing||
October 2018 update: South Korea's online e-procurement system appears to be well maintained and the above report on ‘achievements’ shows that from 2016 to 2017 there has been a substantial increase in public organisation users and business users of the system.
|Public procurement||South Korea public procurement service- achievements|
|Access to Domestic Law Enforcement||23/10/2018||We commit to employ all available means to meet the FATF standards on beneficial ownership that may include law enforcement agencies have full and effective access to beneficial ownership information for companies and other legal entities||South Korea||Ongoing||
October 2018 update: It is now required in South Korea for financial institutions to identify the beneficial ownership of customers. And in this report from TI-S, on page 41 it shows their G20 score on transparency of financial institutions has increased from 31% in 2015 to 50% in 2017. There does seem to be a lot of gaps though, as overall in the G20 beneficial ownership report, South Korea is deemed as having a ‘weak framework’.
|Beneficial ownership||TI G20 leaders or Laggards|
|Legislation||23/10/2018||We commit to strengthen our asset recovery legislation, and support a broader use of regional asset recovery practitioners’ network, such as ARIN-AP which Korea holds a role of Secretariat.||South Korea||Inactive||
October 2018 update: There does not seem to be any action to ‘support a broader use of regional asset recovery practitioners’ networks’. The above link outlines what the current developments in South Korea are in relation to asset recovery and there is no mention of supporting regional asset recovery practitioners’ networks nor is there is mention of strengthening legislation.
|Asset recovery||Law Review country profile|
|Legislation||23/10/2018||Spain commits to implement the robust provisions of the Penal Code in the fight against corruption.||Spain||Ongoing||Law enforcement||Commitment 14 as outlined by the Spanish Government - Information on relevant laws and amendments The Repository of Data on Judicial Procedures for Corruption|
|International Anti-Corruption Coordination Centre||23/10/2018||Spain welcomes the UK initiative to establish an independent International Anti-Corruption Coordination Centre (IACCC) and expresses its willingness to collaborate with this Centre, as well as the readiness of the Spanish law enforcement bodies to keep fighting grand corruption and boosting international cooperation.||Spain||Underway||Law enforcement||Commitment 21 as outlined by the Spanish Government - Spain expresses their support of the Centre|
|Transparency and Integrity||23/10/2018||Spain will set up a governance scheme aimed at detecting non-compliance or problems of systemic character within the public procurement procedures. Results of this activity of surveillance and supervision will be properly disclosed.||Spain||Complete||
October 2018 update: "Law 9/2017, of November 8, on Contracts of the Public Sector, by which the Directives on recruitment 2014/23 / UE and 2014/24 / UE, of February 26, 2014, are transposed within its Book Four (articles 328 to 334) a scheme of three collegiate bodies (the Public Procurement Advisory Board of the State, the Cooperation Committee on Public Procurement and the Independent Office for Regulation and Supervision of Procurement) with the dual objective of to comply with the governance obligations established in the aforementioned Directives and with the recommendations of the European Union, and to combat irregularities in the application of public procurement legislation."
|Public procurement||Commitment 10 as outlined by the Spanish Government - Articles 328 - 334 of Law 9/2017 established Law 9/2017, of November 8, on Contracts of the Public Sector|
|Corrupt Bidders||23/10/2018||Spain commits to exploring ways of sharing information on corrupt bidders across borders.||Spain||Complete||
October 2018 update: The Law on Public Sector Contracts introduces mechanisms to improve transparency in public procurement as a prerequisite to increase competition, assuming that trace-ability and transparency in decision-making is essential for an efficient operation of procedures, including effective fight against corruption and fraud. Law 9/2017, of November 8, on Contracts of the Public Sector, by which the Directives of the European Parliament and of the Council 2014/23 / EU and 2014/24 / EU, of February 26 are transposed into the Spanish legal system of 2014.
|Public procurement||Commitment 15 as outlined by the Spanish Government Law 9/2017, of November 8, on Contracts of the Public Sector|
|Property & Public Contracting||23/10/2018||Spain will take steps to ensure transparency of the ownership and control of all companies involved in property purchase and public contracting||Spain||Complete||
October 2018 update: "The access to the Database of Real Holder (BDTR) allows knowing the final beneficiary or real owner of the participations of a Spanish company, independently of the operation that is going to be carried out.
|Beneficial ownership||Commitment 4 as outlined by the Spanish Government - Relevant Databases and Registers|
|Public Contracting||23/10/2018||Punish corruption by preventing corrupt bidders and those who seek to hide their beneficial owners from accessing public contracts and procurement by establishing accessible central databases and address ways of sharing information on corrupt bidders across borders.||Ukraine||Overdue||
October 2018 update: Memorandum on the Information Disclosure on Beneficial Ownership signed on May 22nd 2017 has implementation date 31 December 2017. Since it was signed no improvements have been done.
July 2018 update: Memorandum initiated by Global Partnership on the Information Disclosure on Beneficial Ownership signed on May 22nd 2017. No change since 2017.
|Beneficial ownership||Memorandum initiated by Global Partnership on the Information Disclosure on Beneficial Ownership signed on May 22nd|
|Open Contracting||23/10/2018||Protecting against and exposing misuse of public funds by continuing to make public procurement via e-platforms open by default to all, and sharing experiences by participating with Mexico and others in an international ‘Contracting Group’.||Ukraine||Ongoing||
October 2018 update: Reform of public procurement is ongoing and with no end date. As to the cooperation with Mexico there were slow changes after the declarations within The Contracting Five (http://www.contracting5.org/)
|Public procurement||Open Contracting Partnership - Ukraine Profile - e-procurement portals Contracting 5|
|Legislation||23/10/2018||Improve asset recovery legislation, in particular implementing EU Directive 2014/42||Ukraine||Inactive||
October 2018 update: No change.
June 2018 update: Law 2016, № 11, Article 129 improved the fundamentals of the National Agency of Ukraine on identifying, tracing and managing assets received from corruption and other crimes. These amendments followed on from the recommendations contained in the sixth report of the European Commission on the state of Ukraine's liberalisation action plan for Ukraine.
|Asset recovery||Law 2016, № 11, Article 129 - Improving the fundamentals of the National Agency of Ukraine|
|International Anti-Corruption Coordination Centre||23/10/2018||Welcoming to establish an International Anti-Corruption Law Enforcement Coordination Centre and expressing willingness to cooperate with it.||Ukraine||Inactive||
October 2018 update: Nothing changed since the previous update. There was no deadline set for fulfilment of the commitment
|Law enforcement||IACCC website does not state Ukraine as a partner or a prospective partner|
|Information collection, sharing, availability||23/10/2018||Putting in place mechanisms to verify the accuracy of the Beneficial Ownership information provided by companies and enforce compliance with the obligation to submit this information by June of 2017.||Ukraine||Inactive||
October 2018 update: There are no developments on this commitment
June 2018 update: Ukraine has not introduced verification mechanisms yet. Not yet overdue (deadline is end of 2018).
|Beneficial ownership||Legislation on company ownership disclosure in Ukraine - Ukraine has not introduced verification mechanisms yet.|
|Global Asset Recovery Forum||23/10/2018||To support victims, take further steps to improve asset recovery legislation, in particular implementing EU Directive 2014/42, operationalise the National Agency for Detection, Tracing and Management of Proceeds of Corruption and Other Crimes in 2017 and participate with others in the International Asset Recovery Forum 2017.||Ukraine||Complete||
October 2018 update: The National Agency for Detection, Tracing and Management of Proceeds of Corruption and Other Crimes is operational for a year
June 2018 update: During the Global Forum on Asset Recovery in December 2017, Ukraine was a focus, among others, for asset recovery efforts.
|Asset recovery||Global Forum on Asset Recovery Communiqué The National Agency for Detection, Tracing and Management of Proceeds of Corruption and Other Crimes DIRECTIVE 2014/42/EU OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL|
|Access to International Law Enforcement||23/10/2018||Committing to implement bilateral agreements that provide full and effective access for law enforcement agencies and financial intelligence units of a partner country to information on the final beneficiaries of the companies registered in the territory of another partner country||Ukraine||Inactive||Beneficial ownership||Global Forum on Asset Recovery (GFAR) - Guide to Beneficial Ownership Information in Ukraine: Legal Entities and Legal Arrangements|
|Protecting Whistleblowers||23/10/2018||The UK is committed to providing effective protections for whistleblowers and made recent legislative changes to make the system more transparent. The UK will review the effectiveness of these changes||UK||No-data||
October 2018 update: We have not seen any evidence that this is progressing (or evidence that it isn't), but the Anti-Corruption Strategy gives us a deadline for this commitment of 31 December 2019 and tells us which regulations are to be reviewed.
June 2018 update: The UK's Anti-Corruption Strategy 2017-22 states that in 2018/19 the UK will 'Review in 2018/19 the recent changes to the whistle-blowing framework, as introduced by the Enterprise and Regulatory Reform Act 2013'
|Whistleblower/civil society space protection||HM Government, United Kingdom Anti-corruption Strategy 2017-2022|
|Property & Public Contracting||23/10/2018||The UK will also establish a public register of company beneficial ownership information for foreign companies who already own or buy property in the UK, or who bid on UK central government contracts.||UK||Overdue||
October 2018 update: The Government have now published a draft bill for a public register of the beneficial owners of companies that own or buy property, and has set out that it intends to publish this same data for winners of public contracts separately.
June 2018 update: The UK opened a call for evidence on a beneficial ownership register to increase the transparency of overseas investment in property and public contracts in April 2017.
|Beneficial ownership||UK Public Register of Overseas Entity Beneficial Ownership:Written statement Open Government Partnership Property ownership and public contracting by overseas companies and legal entities: beneficial ownership register - consultation Draft Registration of Overseas Entities Bill|
|Global Asset Recovery Forum||23/10/2018||The UK will work with others to establish a Global Forum for Asset Recovery and will provide resources to support it. We will co-host the inaugural meeting of the Global Forum with the United States of America in 2017, focusing on Nigeria, Ukraine, Tunisia and Sri Lanka.||UK||Complete||
June 2018 update: The Global Forum on Asset Recovery was held in Washington, DC, from 4-6 December 2017
|Asset recovery||Global Forum on Asset Recovery (GFAR) Accountable asset return|
|Corrupt Bidders||23/10/2018||The UK will introduce a conviction check process to prevent corrupt bidders with relevant convictions from winning public contracts, and is committed to exploring ways of sharing such information across borders.||UK||Overdue||
October 2018 update: The UK did not deliver against this commitment by its own deadline (December 2017), and we have not seen any public evidence that the Crown Commercial Service has introduced this new check.
June 2018 update: The UK's Anti-Corruption Strategy 2017-22 reiterated this commitment, stating that a trial conviction check process would begin in December 2017. As of the end of March 2018, this trial has not yet started.
|Public procurement||HM Governemtn, United Kingdom Anti-corruption Strategy 2017-2022|
|Public Register||22/10/2018||The UK’s public central register of company beneficial ownership information for all companies incorporated in the UK will be launched in June 2016.||UK||Complete||The UK’s public register of beneficial ownership information was published at the end of June 2016, and was the first of its kind in the world.||Beneficial ownership||UK Companies House Persons of Significant Control Register|
|Open Contracting Data Standard||22/10/2018||The UK Crown Commercial Service will implement the Open Contracting Data Standard by October 2016. The UK is trialling the principles of this Standard in High Speed Two (HS2). The UK will join the new Contracting 5 group to promote open contracting globally.||UK||Complete||The UK implemented the Open Contracting Data Standard in November 2016. In doing so, it became the first G7 country to commit to the Open Contracting Data Standard for contracts administered by the Crown Commercial Service. The whole process of awarding public sector contracts is now visible to the public for the first time.||Public procurement||Gov.uk Criminal Finances Bill|
|Legislation||22/10/2018||The UK is consulting on stronger asset recovery legislation, including non-conviction based confiscation powers and the introduction of unexplained wealth orders.||UK||Complete||The UK's consultation into unexplained wealth orders closed in 2016, and UWOs have since come into force.||Asset recovery||Unexplained Wealth Orders a landmark moment in fight against corruption|
|International Anti-Corruption Coordination Centre||22/10/2018||The UK will work with others to establish an International Anti-Corruption Coordination Centre and will provide people and resources to support it.||UK||Complete||The International Anti-Corruption Coordination Centre was launched on 5 July 2017||Law enforcement||National Crime Agency|
|Public Register||22/10/2018||New Zealand commits to exploring the establishment of a public central register of company beneficial ownership information.||New Zealand||Ongoing||
October 2018 update: On 19 June 2018, the Ministry of Business, Innovation and Employment released a discussion document seeking feedback on what requirements there should be on New Zealand companies and limited partnerships to hold and disclose information about their beneficial owners. Submissions closed on 3 August 2018. Limited progress has been made therefore. Interest has been indicated to progress this ahead of the EU by the current Speaker of the House, Justice Minister and Minister Open Data.
June 2018 update: Limited progress has been made but as there is no deadline it is hard to measure progress. The Ministry of Business, Innovation and Employment (MBIE) is exploring the establishment of a public central register of company beneficial ownership information. At the Financial Action Task Force (FATF) meetings in February 2017, MBIE met with officials from a range of countries to better understand how other countries are exploring and implementing beneficial ownership registers. MBIE also met with officials from the UK Treasury and UK Department for Business, Energy and Industrial Strategy in London. MBIE has noted that it intends to consult with stakeholders on this issue later this year (2017).
|Beneficial ownership||Call for feedback on what requirements there should be made on the New Zealand companies and limited partnerships to disclose beneficial owners|
|Debarment Database||22/10/2018||We commit to establishing accessible databases of companies with final convictions.||Mexico||Underway||
October 2018 update: The registry has been updated to 2018, however there is no historic data of the registry.
June 2018 update: Though there is a public list in open data format of public suppliers and sanctioned contractors, this list has not been recently updated.
|Public procurement||Sanctioned suppliers and contractors|
|Property||22/10/2018||We will take steps to ensure transparency of the ownership and control of all companies involved in property purchase and public contracting.||Mexico||Underway||
October 2018 update: The Ministry of Public Affairs (Secretaria de la Función Pública) created a sub- working group on beneficial ownership
July 2017 update: Conversations have started regarding beneficial ownership registers, such as the seminary "Technical Considerations for the Development of a Beneficial Ownership Registry", which aimed to identify international experiences regarding the subject which could be applied for a registry in Mexico.
|Beneficial ownership||SFP participates in international seminar on Final Beneficiary The Ministry of Public Affairs (Secretaria de la Función Pública) created a sub- working group on beneficial ownership|
|Central Register||22/10/2018||We commit to exploring interoperability of different data bases regarding public contracts information and business registries.||Mexico||Underway||
October 2018 update: The Ministry of Public Affairs (Secretaria de la Función Pública) created a sub- working group on beneficial ownership.
July 2017 update: The installation of the Alliance for Open Contracting in Mexico (Alianza para las Contrataciones Abiertas en Méxcio) aims to implement the Open Contracting Data Standard (in it's Mexican adaptation) in public contracting. The implementation of the standard implies interconnectivity with other databases. Additionally, conversations have started regarding beneficial ownership registers, such as the seminary "Technical Considerations for the Development of a Beneficial Ownership Registry", which aimed to identify international experiences regarding the subject which could be applied for a registry in Mexico. No change since 2017.
|Beneficial ownership||Alliance for Open Contracting The Ministry of Public Affairs (Secretaria de la Función Pública) created a sub- working group on beneficial ownership|
|Data Literacy||22/10/2018||We commit to promote coherent use of digital technologies across policy areas and levels of government in the fight against corruption.||Mexico||Ongoing||
October 2018 update: Through the creation of the National Digital Platform new technologies are being explored
June 2018 update: No change.
July 2017 update: The creation of the National Digital Platform aims to interconnect the different information systems in the government in order to prevent, detect, and investigate corruption acts. No change since 2017.
|Open data||Decree issuing the General law of the National anti-corruption system; The General law of administrative responsibilities, and the Organic Law of the Federal Court of Administrative Justice. SFP and SESNA install permanent table for the construction of the National digital platform What is the Anti-corruption Opening Guide?|
|Access to Domestic Law Enforcement||22/10/2018||We commit to promote that law enforcement agencies at the national/federal level, have full and effective access to beneficial ownership information for companies and other legal entities registered within their jurisdiction.||Mexico||Ongoing||
October 2018 update: Conversations on the topic have started.
June 2018 update: No change.
July 2017 update: In the TI-S report 'G20 Leaders or laggards? Reviewing G20 promises on ending anonymous companies', 'G20 Principle 4: Access to Beneficial Ownership Information' shows that in both 2015, and 2017, Mexico achieved the same score.
|Beneficial ownership||G20 Leaders or laggards? Reviewing G20 promises on ending anonymous companies- Spotlight on Mexico SFP participates in international seminar on final beneficiary|
|Central Register||22/10/2018||Kenya welcomes the establishment of transparent central registers of foreign and local companies bidding on public contracts and buying property, and will pursue options for taking similar action.||Kenya||Ongoing||
October 2018 update: The executive order does not speak of the establishment of a central depository of the all tenders awarded and their particulars
June 2018 update: An Executive order has been issued requiring all government entities and public owned institutions to publish full details of tenders and awards from 1st July 2018. The details to include particulars of the companies awarded the contracts such as directors and owners (including beneficial Owners).
|Beneficial ownership||President Uhuru Kenyatta orders full public disclosure of details of Government tenders Executive Order No 2 of 2018|
|Access to Domestic Law Enforcement||22/10/2018||Kenya commits to ensuring that international and domestic law enforcement agencies have full and effective access to beneficial ownership information for companies and other legal entities registered within their jurisdiction.||Kenya||Ongoing||
October 2018 update: The drafting of the regulations has opened up a discussion regarding who gets to access the information in the database - stakeholder validation discussions.
June 2018 update: The Companies Amendment Act 2017 requires companies to disclose names and addresses of Beneficial Owners. Additionally the Business Registration Service has since designed the forms that Companies will use to collect information on beneficial owners . The forms are however yet to be Gazetted.
|Beneficial ownership||The Companies Amendment Act 2017|
|Public Register||22/10/2018||Ghana is committed to preventing the misuse of companies and legal arrangements to hide the proceeds of corruption and commits to strengthening further both the Companies Bill and the Petroleum (Exploration and Production) Bill that are currently before Parliament to ensure that we have public beneficial ownership information and central register for all sectors, including oil and gas sector, in line with UNCAC and FATF Recommendations as well as the Extractive Industries Transparency Initiative (EITI) standards that Ghana is implementing; ensuring that accurate and timely company beneficial ownership information, including in the extractives, is available and accessible to the public||Ghana||Ongoing||
October 2018 update: No change.
June 2018 update: The BO clauses have been included in the Amended Company Act 2016, however, a regulation is yet to be passed for the operationalisation of the law. That notwithstanding, the Registrar General is engaging with civil society on how to implement BO Disclosure in Ghana. A DFID funding mechanism, Strengthening Transparency, Accountability Against Corruption (STAAC) is also engaging the Registrar General by way of supporting the setting of the register once the legal framework is complete.
|Beneficial ownership||Ghana announces partnership with OpenOwnership|
|Open Contracting Data Standard||22/10/2018||Ghana will work towards making government public procurement ‘open by default’ – beginning with Open Contracting Data Standards for high value contracts and contracts in the oil, gas and mining sector||Ghana||Overdue||Ghana has set up an open data centre, however there is much more to be done if Ghana is going to promote Open Contracting Data Standards. Currently, The Public Procurement Authority have the Prefix which is the first phase of getting incorporated in Ghana's Open Data Initiative. The Public Procurement Authority has indicated that the E-procurement will be on-stream by August 2018||Public procurement||Deputy Minister for Energy, Dr. Mohammed Amin Adam, has said the legal and regulatory framework for open contracting for the oil and gas sector will be ready by June 2018.|
|Debarment||22/10/2018||Ghana is committed to exploring further options for improving transparency and openness in the area of public contracting and will continue to blacklist and debar service providers and contractors who engage in corrupt and other related misconduct in public procurement.||Ghana||Overdue||
October 2018 update: No change.
June 2018 update: The Amended Public Procurement Act 2016 (Act 914) has included Debarment (Section 3q). Implementation of the Act is pending and then a guideline will be developed on debarment. A draft regulation has been prepared and validated as of 12-04-2018.
|Public procurement||The Amended Public Procurement Act 2016 (Section 3q, pg.8)|
|Reporting Corruption||22/10/2018||Ghana is strengthening the necessary legislative and other measures to enhance the capacity of the public/citizens and encourage them to report corruption without fear of victimization, and commits to: · improve and extend the recently established Citizens complaints Centre in Accra to other regions of the country||Ghana||Complete||
October 2018 update: Witness Protection law passed.
July 2017 update:The Witness Protection Bill has been relaid and read for the first time in Parliament on 24th January, 2018. This has become necessary because a new parliament - the 7th Parliament of the 4th Republic was constituted after the 2016 general elections.
|Whistleblower/civil society space protection||Witness protection law passed Witness Protection Bill 2017 at second reading|
|Open Contracting Data Standard||22/10/2018||Bulgaria commits to the implementation of the Open Contracting Data Standard as part of its new e-government procurement work.||Bulgaria||Underway||
October 2018 update: Since 2017 the Public Procurement Agency (PPA) have been implementing a new web-based procurement portal. According to the agreement with the developer, the new e-procurement system will incorporate Open Contracting Data Standard. The first phase of the implementation is expected to conclude in October 2018 and the new portal will be launched with part of all perceived functionalities. The system should be fully developed by 1 January 2021. In June 2018 the PPA proposed amendments to the Public Procurement Act aiming at adjustment of the legislation to the practical use of the portal. The draft law has been submitted to the Parliament on 1 August 2018.
June 2018 update: In March 2017 the Public Procurement Agency launched a procedure for selection of contractor to implement a new web-based procurement portal. The contract has been concluded in December 2017. According to it, an e-procurement system should be implemented following the Open Contracting Data Standard. The execution deadline is set 36 months.
|Public procurement||Full text of the Contract Agreement The procurement procedure for development of the e-portal file Draft law for amendment of the Public Procurement Act|
|Transparency and Integrity||22/10/2018||Bulgaria commits to keeping public contracting and government budgets open and transparent to prevent and expose the theft and misuse of taxpayers’ money.||Bulgaria||Ongoing||
October 2018 update:The Public Procurement Agency maintains a publicly available register of all tenders launched in the country. According to the Public Procurement Act, all public bodies are obliged to publish tendering documentation and certain set of information for each separate procedure on their websites. With the implementation of the new e-procurement system, it is expected that information about all tenders conducted in the country will be available at a single portal. The system should be fully implemented by 1 January 2021. Also, in June 2018 the PPA proposed amendments to the Public Procurement Act, which among others provide for publication of all agreements with subcontractors, concluded between the latter and the selected contractor. These measures should be recognized as a step forward to increasing of transparency of the public procurement. However, high standards are yet to be accomplished.
June 2018 update: The Public Procurement Agency maintains a publicly available register of all tenders launched in the country. According to the Public Procurement Act, all public bodies are obliged to publish tendering documentation and certain set of information for each separate procedure. However, high standards are yet to be accomplished.
|Public procurement||Procurement procedures portal Draft law for amendment of the Public Procurement Act|
|Public Register||22/10/2018||Bulgaria commits to exposing illicit financial flows through lifting the veil of secrecy over who owns and controls companies. It already has made public its registry for companies registered under its own jurisdiction and supports internationally recognised measures that ensure accurate and timely information on foreign registered beneficial ownership is made available to all those who need it.||Bulgaria||No data||
October 2018 update: No change since spring 2018.
June 2018 update: There is no publicly available information on specific planned or implemented activities towards introduction of internationally recognised measures on beneficial ownership disclosure.
|Public Contracting||22/10/2018||Bulgaria commits to actively investigating the link between corruption and organised crime. Organised criminals use the proceeds from illicit market activities and contraband to influence the judiciary, law-enforcement, central and local government, and the media in order to facilitate their criminal activities, launder proceeds, or win public contracts for their legal fronts. Profits from public contracts awarded to companies linked to organised crime are used to finance VAT fraud schemes or the illicit trade in excise tax goods or drugs. Seizing the profits of organised criminals and denying access to public contracts of their front companies is key to tackling corruption.||Bulgaria||No data||
October 2018 update: No change since spring 2018.
June 2018 update: This is the most important commitment, but so far no particular solution has been proposed, a mechanism is not in place to limit the access of "dirty money" into the public governance process through the public procurement system.
|Accountable Repatriation||22/10/2018||Bulgaria commits to providing technical assistance and expertise on asset recovery and welcomes international cooperation on transparent and accountable management of returned assets.||Bulgaria||Ongoing||
October 2018 update: No change since spring 2018.
June 2018 update: CIAF participates in a number European and international networks dealing with confiscation of illegal assets, including CARIN, SIENA, ARO platform, ECAB, MONEYVAL committee, etc. Representatives of the Commission continuously participate in bilateral and multilateral meetings and events. Detailed information on international cooperation have been provided in the CIAF's activity reports for 2016 year (p. 35) and for 2017 (p. 31).
|Asset recovery||Committee for Combating Corruption and the withdrawal of illegally acquired property Activity report for 2017 Committee for Combating Corruption and the withdrawal of illegally acquired property Activity report for 2016|
|Legislation||22/10/2018||Bulgaria commits to uncovering, seizing and returning the proceeds of corruption to their legitimate owners. Bulgaria’s Commission for the Withdrawal of Criminal Assets has gained strength and considerable experience in recovering and confiscating illicit proceeds and will benefit from its proposed inclusion in a new powerful Anti-corruption Bureau proposed under the Draft Corruption Prevention and Confiscation of Criminal Assets Act. The draft Law focuses on cases of unexplained wealth and allows for the reversal of burden of proof.||Bulgaria||Ongoing||
October 2018 update: No change since spring 2018
June 2018 update: In early 2018 the new anti-corruption law (Prevention of Corruption and Forfeiture of Illegal Assets Act) has been adopted and a new Commission for prevention of corruption and forfeiture of illegal assets established. This new body merges the former Asset Forfeiture Commission (CIAF), the former Conflict of Interests Commission, the former Centre for Prevention and Fight against Corruption and Organised Crime, and departments of the National Audit Office and the State Agency for National Security being in charge in prevention of corruption among high public officials. The law changes the structure and management model of the listed bodies, but does not upgrade the confiscation system. The amount of actually collected assets remains low. The only improvement worth to mention is the regulation for allocation of 30% of confiscated assed for social purposes, however the exact mechanism is yet to be set.
|Asset recovery||New anti-cottuption law- 'Prevention of Corruption and Forfeiture of Illegal Assets Act'|
|International Anti-Corruption Coordination Centre||22/10/2018||Australia will work with the UK and others to establish the new International Anti-Corruption Coordination Centre, to streamline and focus international cooperation in cases of grand corruption with international dimensions.||Australia||Complete||No change since 2017. Australia joined IACCC.||Law enforcement||International Anti-Corruption Coordination Centre|
|Open Contracting Data Standard||22/10/2018||Australia supports the Open Contracting Data Standard, and notes the role the Standard can play in encouraging machine-readable open data formats across all areas of government.||Australia||Underway||
October 2018 update: Further steps on this expected to be included in 2nd OGP National Action Plan
June 2018 update: The Government has agreed that the Department of Finance will "further investigate opportunities to publish existing contracting data in an OCDS compliant format to increase Australia’s compliance with the OCDS. The Government will keep the OCDS in mind when making iterative improvements to the Commonwealth Procurement Framework and the AusTender platform - specifically the data collection and publication processes and requirements - to continue to increase its compliance with the OCDS where possible and approriate to do so".
|Public procurement||Commitment 4.3 of the Open Government National Action Plan - Open Contracting|
|EITI||22/10/2018||We welcome the new 2016 EITI Standard, in particular the requirements on beneficial ownership and the sale of the state’s share of production.||Australia||Underway||
October 2018 update: MSG has met on 3 occasions, gap analysis underway to assess current Australian alignment with 2016 EITI Standard. Despite support from industry, EITI implementation progress has moved slowly so far.
June 2018 update: Australia is preparing it’s application for EITI Candidate Country Status but the process is delayed.
|Beneficial ownership||Open Government Partnership - Australia's Profile - Application for EITI Country Candidate Status|
|Protecting Whistleblowers||22/10/2018||Australia is developing strengthened whistleblower protections designed to protect those who disclose information on tax misconduct to the Australian Taxation Office. Whistleblowers will have their identity protected and will be protected from victimisation and civil and criminal action to encourage them to come forward and help support compliance with Australia’s tax laws.||Australia||Ongoing||
October 2018 update: Awaiting Ministerial decision
June 2018 update: A first stage of legislation (covering all corporate misconduct, not just tax matters) introduced to Parliament in December 2017 but not yet passed, due to it not being up to standard against a very strong parliamentary committee report tabled September 2017
|Whistleblower/civil society space protection||Treasury Laws Amendment( Enhancing Whistleblower Protections) Bill 2017|
|Information collection, sharing, availability||22/10/2018||Australia has tracing powers for beneficial ownership of listed companies and investment schemes and is committed to ensuring that adequate, accurate and timely information on beneficial ownership and control is available to competent authorities.||Australia||Inactive||June 2018 update: An ASIC enforcement review was done at the end of 2017 due to OGP NAP1 Goal 1.4. However, the final report does not mention tracing powers for beneficial ownership.||Beneficial ownership||Australian Securities & Investments Commission Review|
|Legislation||22/10/2018||Australia has effective laws for asset recovery, including non-conviction based confiscation powers and unexplained wealth orders. We will continue to review our legislative framework to ensure its continued effectiveness.||Australia||Inactive||No clear path on next steps.||Asset recovery||Ongoing review of AML regime|
|Open Contracting Data Standard||22/10/2018||Working towards phased implementation of the principles of the Open Contracting Data Standard, focusing on major projects as an early priority||Afghanistan||Ongoing||
October 2018 update: National Procurement Authority completed the development of a platform that contains OCDS standards on information disclosure. The platform was launched on August 8, 2018.
July 2017 update: The National Procurement Authority of Afghanistan has signed a trilateral agreement with Open Contracting Partnership-OCP and Integrity Watch Afghanistan-IWA to implement OCDS in Afghanistan. With the technical support of OCP, NPA has managed to complete the first draft of field level mapping and systems mapping in accordance with the OCP guidelines. Furthermore, all the data points of the five stages of Open Contracting Data Standards-OCDS have been considered to be captured in Afghanistan’s procurement systems. In addition to the major data points of OCDS, NPA has managed to establish a comprehensive Contract Progress Monitoring System for the fifth stage of OCDS i.e. contract implementation. At this stage all the required information is being published about above threshold projects in NPA’s website. Furthermore, the OCP and World Bank-WB’s joint mission visited Afghanistan from 14th July 2017, till 23rd July 2017 to conduct the initial Open Contracting Assessment in Afghanistan. Through this assessment the level of contract openness will be assessed in both the demand and supply sides in the country. The assessment report will be finalized in September 2017 and will provide NPA with specific recommendations for fulfilling Open Contracting Data Standards.
|Public procurement||Open Contracting Annual Report 2017 Awarded Contracts Portal Procurement Reform in Afghanistan (page 21)|
|Debarment Database||22/10/2018||Establishing accessible central databases of companies with final convictions||Afghanistan||Ongoing||No progress since 2017. National Procurement Authority has established a central repository of all those companies who have been debarred in the past but have completed their debarment period, or are currently under debarment sanctions and cannot participate in public procurement, or are under debarment process right now but the final decision is yet to be made. The data about such companies are fully open and it can be accessed through NPA website. However, the final conviction of the debarred companies by AGO has not been published.||Public procurement||Afghanistan's Debarment Database|
|Corrupt Bidders||22/10/2018||Exploring ways of sharing information on corrupt bidders across borders||Afghanistan||Ongoing||No progress since 2017. National Procurement Authority-NPA, initiated the process to pave the way for cross-border debarment. Different countries have different legal and regulatory environments which are specific to the context and requirements of those countries. Coupled with the need for coordinated regional and global action, cross-border debarment has become near to impossible in practice.||Public procurement||Government of Afghanistan Debarment Database|
|Public Register||22/10/2018||Establishing public central registers of company beneficial ownership information||Afghanistan||Ongoing||
October 2018 update: Afghanistan mining law has been recently passed by the cabinet that obliges contractors to declare their beneficial ownership.
June 2018 update: No change.
July 2017 update: Two separate but related initiatives are underway to establish the legal framework for registering of beneficial ownership in Afghanistan. Afghanistan EITI started to work on beneficial ownership one year back with an exclusive focus on companies active in the extractive sector. A roadmap has been prepared and some progress has been made. However, the mining law has not been amended to encompass beneficial ownership registration. Afghanistan Central Business Registry (ACBR) has come up with a new website that published shareholders of the companies. In addition, ACBR, as well as National Procurement Authority as well as a civil society organization, Integrity Watch Afghanistan, have prepared a proposal for the government on introducing beneficial ownership registration and publication across the sectors. The proposal is depending the High Economic Council’s approval before actual work on development of a legislation begins.
|Beneficial ownership||Afghanistan Central Business Registry Cabinet of Ministers' under the chairmanship of President Ghani approve a number of laws|
|Automatic Exchange of Information||22/10/2018||Joining the pilot initiative for automatic exchange of beneficial information||Afghanistan||No data||No progress since 2017.||Beneficial ownership|
|Public Contracting||22/10/2018||Taking steps to ensure transparency of the ownership and control of all companies involved in property purchase and public contracting. Supporting the establishment of transparent central registers of foreign companiesbidding on public contracts and buying property, and intend to explore options for taking similar action.||Afghanistan||No data||No progress since 2017||Beneficial ownership|
|Property||22/10/2018||Taking steps to ensure transparency of the ownership and control of all companies involved in property purchase and public contracting. Supporting the establishment of transparent central registers of foreign companies bidding on public contracts and buying property, and intend to explore options for taking similar action.||Afghanistan||No data||No progress since 2017.||Beneficial ownership|
|Asset Recovery Guidelines||22/10/2018||Developing internationally endorsed guidelines for the transparent and accountable management of returned stolen assets.||Afghanistan||No data||No change since June 2018. Ministry of Justice developed and promote laws regarding the defence of public assets and they returned a huge number of property and asset to government based on the Government cases law. The Ministry has done other things but not this specific commitment. Therefore, it is inactive.||Asset recovery|
|Legislation||22/10/2018||Strengthening asset recovery legislation, including through nonconviction based confiscation powers and the introduction of unexplained wealth orders||Afghanistan||No data||No progress since 2017. "There is no significant progress here."||Asset recovery|
|Protecting Whistleblowers||22/10/2018||We commit to strengthen whistle blower system and protect those who have provided information on corruption||Indonesia||Complete||No change since 2017. Corruption Eradication Commission (KPK) signed Memorandum of Understanding with the Witness and Victim Protection Agency (LPSK) will provide maximum protection for those who have provided information on corruption.||Whistleblower/civil society space protection||Joint Efforts by LPSK and KPK to Protect Witnesses of Corruption Cases- CNN Indonesia|
|Transparency and Integrity||22/10/2018||We will work toward the full implementation of the principles of the G20 Principles for Promoting Integrity in Public Procurement and the relevant provisions in United Nations Convention Against Corruption.||Indonesia||Complete||No change since 2017.||Public procurement||LPSE electronic government procurement system|
|Debarment Database||22/10/2018||We commit to strengthen central databases of public contracting companies with final convictions.||Indonesia||Complete||No change since 2017.||Public procurement||Active Blacklist|
|G20 Open Data Principles||22/10/2018||We will work toward the full implementation of the G20 Anti-Corruption Open Data Principles.||Indonesia||Complete||No change since 2017.||Open data||REGULATION OF THE PRESIDENT OF THE REPUBLIC OF INDONESIA YEAR 2017 REGARDING DATA|
|Public Register||22/10/2018||We commit to exploring the establishment of public central registers of company beneficial ownership information||Indonesia||Complete||"To prevent and eradicate corruption, specifically the crime of money laundering and terrorism financing, the government has issued Presidential Regulation Number 13 of 2018 on the Implementation of Know your Beneficial Owner Principle Regulation Number 13 of 2018 on the Implementation of Know Your Beneficial Owner Principle by Corporations to Prevent and Eradicate Money Laundering and Financing of Terrorism (Regulation 13/2018). In Regulation 13/2018, every corporation is required to disclose its beneficial owner." Article 29 outlines that everyone can make a request for information about the beneficial owners of corporations to the authorities/law enforcement agencies.||Beneficial ownership||Presidential regulation number 13/2018: implementation of know your beneficial owner principle by corporations to prevent and eradicate money laundering and financing of terrorism|
|Information collection, sharing, availability||22/10/2018||We commit to improving the transparency of the beneficial ownership of legal persons and legal arrangements to prevent misuse of these entities and arrangements for corruption, tax evasion, terrorist financing and money laundering.||Indonesia||Complete||"To prevent and eradicate corruption, specifically the crime of money laundering and terrorism financing, the government has issued Presidential Regulation Number 13 of 2018 on the Implementation of Know your Beneficial Owner Principle Regulation Number 13 of 2018 on the Implementation of Know Your Beneficial Owner Principle by Corporations to Prevent and Eradicate Money Laundering and Financing of Terrorism (Regulation 13/2018). In Regulation 13/2018, every corporation is required to disclose its beneficial owner. "||Beneficial ownership||Presidential Regulation Number 13/2018: Implementation of Know your beneficial owner principle by corporations to prevent and eradicate money laundering and financing of terrorism|
|StAR||22/10/2018||We commit to strengthen the Stolen Asset Recovery Initiative (StAR) in support of countries’ efforts to recover and return stolen assets||Indonesia||Complete||No change since 2017. Strategy 2012-2025 on page 6.||Asset recovery||Evaluation of prevention action and corruption eradication related to asset recovery|
|International Cooperation||22/10/2018||We will afford one another the widest measures of cooperation and assistance in asset recovery||Indonesia||Complete||No change since 2017. Strategy 2012-2025 on page 6.||Asset recovery||Evaluation of Prevention Action and Corruption eradication related to asset recovery|
|Compensation||22/10/2018||We will develop common principles governing the payment of compensation to the countries affected, to ensure that such payments are made safely, fairly and in a transparent manner, under the framework of UNCAC.||Indonesia||Complete||No change since 2017. Strategy 2012-2025 on page 6.||Asset recovery||Evaluation of Prevention Action and Corruption Eradication related to Asset Recovery.|
|Accountable Repatriation||22/10/2018||We commit to participate in the second review cycle of the implementation of Chapter V on Asset Recovery of the United Nations Convention Against Corruption.||Indonesia||Complete||No change since 2017. Strategy 2012-2025 on page 6.||Asset recovery||Evaluation of Prevention action and Corruption Eradication related to Asset Recovery|
|Reporting Corruption||27/09/2018||Brazil will continue to strengthen mechanisms to make it easier for citizens to report corruption, to facilitate actions including by law enforcement on the information provided, and to protect “whistle blowers” and others in the public and private employees who take personal risks to unveil corruption activities.||Brazil||Underway||Several measures have been taken recently:
• Law 13.460 of June 26th, 2017, on social participation, protection and guarantee of the rights of public service users. Provides that every entity must have effective channels to receive citizens complaints and other communications, including reports of corruption. It also provides that any personal information about the complainant/whistleblower must be kept secret.
• Law 13.608 of January 10th, 2018, on public hotlines for complaints including reports on corruption. It introduces the possibility for the government to reward citizens that provide information that helps police investigation. It also provides that any personal information about the complainant/whistleblower must be kept secret.
• Interministerial Ordinance 424 of December 30th, 2016 (Portaria Interministerial nº 424/2016) establishes that any municipality that receives money from the Federal Government (with the exception of resources transferred due to legal or constitutional obligations) must have an effective channel for citizens to report irregularities.
• An online system was created by CGU and made available in 2017 for all municipalities with no cost, named E-Ouv Municípios, for them to receive citizens’ complaints in the terms of the Interministerial Ordinance 424 (https://sistema.ouvidorias.gov.br/publico/BuscadorOuvidorias/BuscadorOuvidorias.aspx).
• The topic of whistleblower protection is being widely debated, including within the Brazilian National Anti-corruption Strategy (ENCCLA). There are also several bills under evaluation at the Brazilian Congress that deal with this topic, such as PL 9167/2017 and PL 8727/2.
|Whistleblower/civil society space protection||E-Ouv online system to receive citizens' complaints|
|Information collection, sharing, availability||07/08/2018||We commit to fully implementing the FATF standards on transparency and beneficial ownership of legal persons and arrangements and have taken legislative measures to this effect which entered into force on 1 January 2016.||Switzerland||Underway||FATF mutual evaluation report December 2016: "Switzerland has adopted measures during recent years intended to reinforce the transparency of legal persons: companies must maintain a register of their shareholders/ partners and their beneficial owners, including for companies with bearer shares." "The measures applicable to small associations appear to be insufficient. "the dissuasive character of the applicable sanctions appears to be insufficient, since there are no sanctions of a criminal or administrative nature in the case of shortcomings regarding the reporting obligations. "Switzerland is largely compliant with rec. 24 and 25||Beneficial ownership||FATF mutual evaluation report December 2016|
|Debarment Database||07/08/2018||We commit to exploring ways of establishing central databases of companies with final convictions||Switzerland||Underway||In the context of a total revision of the federal and inter-cantonal public procurement law, the Swiss Government has drafted legislation which provides for a non-public list of convicted companies to be kept by a central authority. The bill was submitted to Parliament on 15 February 2017.||Public procurement||Swiss Government has drafted legislation which provides for a non-public list of convicted companies to be kept by a central authority|
|Compensation||25/06/2018||We will develop common principles governing the payment of compensations by corruption offenders to the countries affected, ensuring that such payments are made safely, fairly and in a transparent manner.||Mexico||No data||No change since 2017.||Asset recovery|
|International Cooperation||21/06/2018||We will prioritise prosecutions of grand corruption and of money laundering and recovery of stolen assets||Sri Lanka||Ongoing||Asset recovery||Special Judicature Bill, which aims to establish a permanent high court focussing on corruption, passed in Parliament JUDICATURE (AMENDMENT) ACT, NO. 9 OF 2018|
|Information collection, sharing, availability||20/06/2018||Brazil is implementing measures and regulations to ensure that information on beneficial owner of companies is obtained, verified, recorded and kept up-to-date||Brazil||Underway||Normative ruling obliges new companies (issuing a tax ID number July 2017 onwards) to inform beneficial owners -- established companies must do the same until 31 December 2018. However, it is not clear if and how the tax authorities are going to share such information with other authorities -- it is not clear either about enforcement and implementation, once the first deadline , 1 January 2017, was postponed until 1 July 2017.||Beneficial ownership||'Register of Beneficial Ownership' from KPMG - Focus on Brazil among others|
|Training and Assistance||20/06/2018||Spain commits to fully develop the functions for which the Asset Recovery and Management Office was created so it becomes a pillar in the fight against crime.||Spain||Complete||No change since 2017.||Asset recovery||Commitment 17 as outlined by the Spanish Government - 'ORGA is fully operational in the entire territory of the State' and other updates|
|Central Register||20/06/2018||The Spanish land registry and registry of movable assets centralize all the information regarding the owners of the land, real estate or movable assets irrespective of the citizenship of the acquiring person. The combined use of this tool and the information available concerning the beneficial ownership information of every company buying one of these properties have proved to be a very useful tool. Spain welcomes the establishment of transparent central registers of foreign companies bidding on public contracts and buying property||Spain||Complete||No change since 2017.||Beneficial ownership||Commitment 5 as outlined by the Spanish Government Property Registration Frequently Asked Questions|
|Transparency and Integrity||20/06/2018||We will include the Principles for Integrity in Public Procurement into our national standard procedure.||Mexico||Complete||Principles for Integrity in Public Procurement are in the national legislation. No change since 2017.||Public procurement||Public sector procurement, leasing and Services Act|
|Open Contracting Data Standard||20/06/2018||We will work towards the implementation of the Open Contracting Data Standard on public procurement starting with major infrastructure projects as an early priority, including the new Mexico City International Airport, in accordance to Mexican regulations.||Mexico||Complete||Data from Mexico City´s new airport is available in the stated portal and is constantly being updated. No change since 2017.||Public procurement||Mexico City International Airport Open Data|
|Open Contracting||20/06/2018||As a founding member of the Contracting 5 (C5), we support the implementation of Open Contracting as an effective monitoring tool to promote accountability and increase transparency worldwide by releasing structured, interoperable and reusable data around procurement's whole lifecycle, including planning, tendering, award, implementation and evaluation stages.||Mexico||Ongoing||No change since 2017.||Public procurement||Alliance for Open Contracting|
|Open Data||19/06/2018||Brazil is committed to make data on public procurement open by default, providing usable, timely and shareable information.||Brazil||Complete||All the information on public procurement is available in the Transparency Portal of the Federal Government (http://www.transparencia.gov.br) and downloadable in open format (http://www.portaltransparencia.gov.br/downloads/). This information can also be accessed in the Open Data Portal (http://dados.gov.br). The information is updated frequently, in some cases daily. Information is also available in the Government Procurement Portal (Portal de Compras Governamentais - https://www.comprasgovernamentais.gov.br/index.php/painel-de-compras-de-governo) and in open format in the Open Data Portal (http://dados.gov.br/dataset/compras-publicas-do-governo-federal).||Public procurement||Transparency Portal of the Federal Government|
|Legislation||18/06/2018||We commit to strengthen asset recovery legislation, including through administrative freezes and non-conviction based confiscation powers.||Switzerland||Complete||On 1 July 2016, the Federal Act on the Freezing and the Restitution of Illicit Assets held by Foreign Politically Exposed Persons entered into force. The new law regulates the freezing, confiscation and restitution of illicitly acquired assets of foreign politically exposed persons and their close associates. It also provides for measures to help states where the illicitly acquired assets originated in their efforts to recover those assets. In the event that the mutual legal assistance process does not succeed, the law allows the Swiss Government to instigate administrative confiscation proceedings which opens the way for returning the assets to the state of origin.||Asset recovery Law enforcement||Federal Act on the Freezing and the Restitution of Illicit Assets held by Foreign Politically Exposed Persons|
|International Anti-Corruption Coordination Centre||18/06/2018||We will actively participate in efforts to establish a new International Anti-Corruption Coordination Centre to complement and help draw together existing structures with a view to streamlining and focusing international cooperation in cases of grand corruption with international dimensions.||Switzerland||Complete||No change since 2017||Law enforcement||Switzerland joins as an observer to the IACCC|
|Corrupt Bidders||18/06/2018||We commit to exploring ways of sharing information on corrupt bidders across borders.||Switzerland||Ongoing||An exchange of information on corrupt competitors among the Swiss cantons is already taking place. A total revision of the federal as well as the inter-cantonal public procurement law is currently underway. The draft legislation submitted by the Swiss Government to Parliament on 15 February 2017 provides for the sharing of information on corrupt bidders among both federal and cantonal procurement authorities. https://www.admin.ch/opc/de/federal-gazette/2017/1851.pdf As soon as an exchange of information at international level is under discussion, Switzerland will examine appropriate proposals.||Public procurement||Draft legislation submitted by the Swiss Government to Parliament on 15 February 2017 providers for the sharing of information on corrupt bidders.|
|Asset Recovery Guidelines||18/06/2018||We commit to engaging in the development of internationally-endorsed guidelines for the efficient recovery of stolen assets.||Switzerland||Complete||Building upon it's experience, Switzerland promotes the development and use of guidelines for the efficient recovery of stolen assets through the Lausanne seminar series. A user-friendly step-by-step guide was finalized in 2017 during Lausanne X and presented at the UNCAC COSP in November 2017.||Asset recovery||Guidelines for the Efficient Recovery of Stolen Assets|
|Access to International Law Enforcement||18/06/2018||We commit to the effective international exchange between law enforcement authorities of beneficial ownership information of companies and other legal persons and arrangements on a case-by-case basis.||Switzerland||Complete||No change since 2017.||Beneficial ownership||FATF mutual evaluation report December 2016|
|Access to Domestic Law Enforcement||18/06/2018||We commit to ensuring that law enforcement agencies have full, timely and effective access to beneficial ownership information for companies and other legal persons registered within our jurisdiction, particularly by ensuring that companies are represented by an administrator or director domiciled in Switzerland||Switzerland||Complete||No change since 2017.||Beneficial ownership||FATF mutual evaluation report December 2016|
|Transparency and Integrity||18/06/2018||Spain will continue to promote maximum transparency in public procurement procedures, only limited by due respect to confidentiality obligations deriving from EU Law (in particular, relevant EU Directives).||Spain||Complete||No change since 2017.||Public procurement||Commitment 9 as outlined by the Spanish Government - Entry into force of the law 9/2017|
|Legislation||18/06/2018||Spain commits to strictly enforce its asset recovery legislation, including through non-conviction based confiscation, extended confiscation and confiscation from a third party.||Spain||Complete||Asset recovery||Commitment 16 as outlined by the Spanish Government - Updates from the Spanish Office for Asset Recovery and Management (ORGA)|
|Global Asset Recovery Forum||18/06/2018||Spain is willing to participate in the Global Forum for Asset Recovery||Spain||Complete||Spain participated in the Global Forum for the Recovery of Assets (Washington DC, 4-6 December 2017), which focused on Nigeria, Sri Lanka, Tunisia and Ukraine, and brought together more than 300 participants from 26 jurisdictions, as well as representatives of international organizations, civil society and the media.||Asset recovery||Commitment 19 as outlined by the Spanish Government- Spain Participates in the Global Forum for the Recovery of Assets in December 2017|
|Central Register||18/06/2018||Spain will continue its commitment to achieve the highest level of transparency, currently guaranteed by the Spanish central register of company beneficial ownership information||Spain||Complete||Beneficial ownership||Commitment 1 as outlined by the Spanish Government - Evidence of maintaining the 'BOE'|
|Open Data Charter||18/06/2018||We commit to implement the International Open Data Charter and explore its Anti Corruption Sector Package as a useful tool to promote greater coherence and collaboration among open data initiatives at a global scale.||Mexico||Complete||Mexico is the first country in the world to implement the Open Up Guide for Anticorruption. In this effort 72 data sources were identified which matched the 30 datasets classified for anticorruption in the Guide. Following the recommendations in the Guide, 7 new datasets were published, 8 are in the process of being published, and 32 improved their quality.||Open data||Open Data Catalog of the Government of the Republic|
|G20 Open Data Principles||15/06/2018||We commit to the implementation of the G20 Anti Corruption Open Data Principles, the identification of best practices related to the use of Open Data to fight corruption and to the continuous work around Open Data in the G20 Anti Corruption Working Group and its Action Plans.||Mexico||Underway||No change since 2017.||Open data||Open Data Catalog of the Government of the Republic.|
|Automatic Exchange of Information||13/06/2018||As one of the signatories of the G5 initiative, Spain is fully committed in the development of the pilot initiative for automatic exchange of beneficial ownership information||Spain||Complete||No change since 2017.||Beneficial ownership||Commitment 6 as outlined by the Spanish Government - Pilot Initiative of G5|
|Asset Recovery Guidelines||13/06/2018||Spain supports the development of internationally-endorsed guidelines for the transparent and accountable management of returned stolen assets.||Spain||Complete||No change since 2017||Asset recovery||Commitment 18 as outlined by the Spanish Government - Spain has partcipated in the following international meetings|
|Accountable Repatriation||13/06/2018||Since last May 6, a central database of bank accounts is fully operational in Spain. Notwithstanding this significant improvement, Spain will continue its commitment to developing adequate tools to strengthen the ability to trace and recover stolen assets.||Spain||Complete||No change since 2017||Asset recovery||Commitment 20 as outlilned by the Spanish Government - Government unit training courses|
|Access to International Law Enforcement||13/06/2018||Spain is committed to ensure Spanish law enforcement authorities share the beneficial ownership information available in the Spanish central database with counterparts in third countries. We call other countries to follow an equivalent commitment in terms of sharing beneficial ownership information.||Spain||Complete||No change since 2017.||Beneficial ownership||Commitment 3 as outlined by the Spanish Government- Office of Asset Localisation (OLA)|
|Access to Domestic Law Enforcement||13/06/2018||Spain will continue its commitment to ensuring that financial intelligence unit, law enforcement agencies and tax agency have full and effective access to beneficial ownership information for companies and other legal entities registered in Spain.||Spain||Complete||No change since 2017||Beneficial ownership||Commitment 2 as outlined by the Spanish Government - BDTR.|
|Reporting Corruption||11/06/2018||Bulgaria commits to ensuring citizens are able to report incidents of corruption without fear of reprisal and with confidence that any credible information they provide will be acted on and their identity protected when necessary. Bulgaria’s Draft Corruption Prevention and Confiscation of Criminal Assets Act has detailed provisions regarding the credibility and admissibility of anonymous signals aiming to encourage citizens to report corruption while protecting their identities.||Bulgaria||Abandoned||In early 2018 the new anti-corruption law (Prevention of Corruption and Forfeiture of Illegal Assets Act) has been adopted. Although in the first draft (2016) there were provisions regarding anonymous reporting, these were later abandoned and the current law provides for processing of signed complaints only. Further, the law focuses over the prevention of corrupt behaviour and conflict of interest among high public officials and requires the compliants to provide evidence in support to their claims. Thus in practice there is no effective mechanism for reporting of wrongdoing by average citizens or lower-level staff. Provisions for protection of whistleblowers from potential reprisal are too vague and compensation might be received in a lawsuit under general regime. Generally speaking, the issue lacks in public communication at all.||Whistleblower/civil society space protection||Prevention of Corruption and Forfeiture of Illegal Assets Act|
|Public Contracting||11/06/2018||Brazil has also taken measures to guarantee that information on the beneficial owner of companies participating in bids and public procurement processes is assembled and verified before the establishment of public contracts.||Brazil||No data||No publicly available information on such measure that would guarantee the collection of Beneficial Ownership information before signing the contract||Beneficial ownership|
|Debarment Database||11/06/2018||Brazil is committed to ensuring full access and transparency of information on companies punished in the terms of the Corporate Liability Law and the Public Procurement Law, through the use of the National Registry of Punished Companies (CNEP) and the Registry of Ineligible and Suspended Companies (CEIS)||Brazil||Underway||Both systems are operational (http://www.portaltransparencia.gov.br/cnep/; http://www.portaltransparencia.gov.br/ceis/). In the terms of Law 12.846/13, all government agencies in all levels of government are obliged to register the information on companies punished. However, Brazil has 5570 municipalities and it takes time to get all of them to comply, especially the smaller ones. In relation to the information on companies punished by agencies of the Federal Government, in July 2017 a new system was launched by the Ministry of Transparency and Comptroller General (CGU), named CGUPJ, to streamline the registration of the information.||Public procurement||Registry of Ineligible and Suspended Companies|