Commenced 5, MARCH, 2013
Concluded 10, MAY, 2013
Submitted By: LACC Assets [Declaration] Verification Team
Approved By: LACC Body of Commissioners
May 20, 2013
UN Drive & Gurley Street
Monrovia, Liberia
Cell: 0886.791.275 / 0777.829.864
laccliberia@gmail.com
I.
Executive summary
The Liberia Anti-Corruption Commission has the broad mandate to investigate, prosecute
and prevent acts of corruption amongst other things (LACC Act of August 2008). Included
in this mandate also is the mandate of LACC to lead the anti-corruption strategy of the
Republic of Liberia, of which the Assets Declarations (AD) by public officials is an integral
part. This strategy, one of which is AD, is very crucial in the prevention and minimization of
corruption. This Strategy has been backed and supported by H.E. the President of the
Republic of Liberia, Madame Ellen Johnson Sirleaf. LACC has explicit faith in the full and
continual support of the President.
As of February 2013, the LACC Body of Commissioners (BOC) decided that AD of public
officials will be vetted. Subsequent to this decision, an AD Verification Team was set up.
The Team was mandated to do a random verification of the AD of Government of Liberia
(GoL) officials. Based on this directive – the AD of sixty-three (63) officials across six (7)
ministries, agencies and public corporations were assessed. The below represents a
snapshot of the findings:
Total AD verified:
63
No. of AD booked for misrepresentations and unexplained wealth accumulation
4
No. of AD not verified because official failed to cooperate
18
No. of AD with outstanding issues – verification process incomplete
8
No. of AD not verified due to written and approved excuse(s)
3
No. of AD verified and found to be truly stated
30
The LACC AD Verification Exercise portends tremendous opportunities for success in the
fight against corruption. It is a maxim amongst corruption fighters that ill-gotten wealth is
going to show up somewhere – in bank accounts, in lifestyles, in personal property
collections and in real estate investments etc. In an open and transparent society, ill-gotten
wealth must not have hiding place(s). Given the challenges in the investigation and
prosecution of persons suspected of corruption, challenges that have been so well
documented at home and abroad, the AD Verification presents a bold new initiative to
prevent and minimize corruption. In the fight against corruption there has to be examples
– good examples made of those who lied on their AD forms, those who failed to file, and
those who are caught spending well above their declared means. Without good examples
made of violators of the public trust, the fight against corruption is doomed.
LACC Assets [Declaration] Verification Report. 05.20.2013
Page 1
Table of Contents
I.
Executive summary
1
II.
Background/Introduction
3
III.
Objectives of the AD Verification Exercise
3
IV.
Procedures Adopted
4
V.
Presentation of Detailed Findings
5
VI.
Conclusions
12
VII.
Recommendations
13
LACC Assets [Declaration] Verification Report. 05.20.2013
Page 2
II.
Background/Introduction
The Liberia Anti-Corruption Commission (LACC) is the cardinal Government of Liberia
(GoL) Agency charged with the responsibility of investigating and prosecuting acts of
corruption and breach of public trust with respect to economic crimes. The LACC is also
responsible for leading Liberia’s anti-corruption strategy, of which assets declaration
(AD) and verification are an integral part. This authority comes from the LACC Act of
2008 (Part V, section 5.1 -5.2). Additionally, the LACC has been mandated by the
President of Liberia to be the sole agency charged with the responsibility of collecting,
storing and otherwise administering the process of GOL officials’ AD.
Assets Declarations systems, the world over, go beyond the mere declaration of assets.
These systems involve the verification of assets and sanctions for violators. Such is the
current reality in post-conflict Rwanda, Sierra Leone and Afghanistan. For any AD
regime to stay relevant, there must be sanctions – sanctions for not filing, sanctions for
late filing and of course sanctions for intentional misrepresentation of the facts. Liberia
AD regime cannot be and must not be any different.
As of February 2013, the Body of Commissioners (BOC) of LACC decided that AD of
public officials, will now, in fact be verified. To implement this exercise, the BOC put
together a team of lawyer, accountant and investigators to implement a vigorous AD
Verification Exercise to ascertain the level of truthfulness public officials accorded the
AD disclosures. The exercise is certainly the first of its kind in Liberia and LACC assures
the public that it will get better with time. Moreover, the LACC BOC is pleased to note
that the AD is a critical component of the fight against graft and that this process is here
and here to stay.
III.
Objectives of the AD Verification Exercise
The specific objectives and quantifiable outputs of this AD Verification Exercise are:
1. to fully vet, verify and certify as truthful or otherwise the AD of at least 60
GoL officials over the period March to May 2013;
2. to ascertain whether assets declared by public officials commensurate
with their past and current sources of income;
3. to identify the prevalence of illicit wealth accumulation as a way of
understanding the scale of the problem of corruption in the society.
LACC Assets [Declaration] Verification Report. 05.20.2013
Page 3
IV.
Procedures Adopted
The process of AD verification starts with the officials being asked via a letter to arrange
an appointment within 10 days of receipt of the LACC’s letter. An appointment is
usually set within the 10 days period, after which interviews are conducted with the
active participation of the official. If all items on the declaration are clear enough, and
the AD Verification Team is satisfied with the declaration, a preliminary clearance is
issued to the official, noting that his/her income/assets/liabilities are truly stated. Unless
new information surfaces that materially contradicts the existing information, the initial
clearance is as good as final.
If for any reason the AD is not clear or question arises, the official is asked to further
clarify or, alternatively, the LACC AD Verification Team makes a field visit to check out
the assets or otherwise do its own verification/evaluation/appraisal of the declarations.
Basis for Selection of the first Batch of Officials
The LACC decided to make the assets verification process random; howbeit with some
minimal parameters so as to maximize its multiplier effect. Additionally, given its limited
resources, which ostensibly meant that LACC could only do a tiny fraction of the
officials who declared assets, the LACC BOC laid out the following minimum criteria as
the core benchmark for the AD Verification Team to select the first batch of officials:
1. Officials managing big-spending GoL ministries/agencies and public corporations
2. Officials managing top-revenue-generating ministries and agencies
3. Officials from ministries and agencies ranking high on the LACC’s corruption
perception index
The AD Verification Exercise was also random with respect to the level of officers
interviewed. The LACC AD Verification Team went beyond the inclination of simply
seeking out the very top officials. Accordingly, as you will note from the detailed
findings, a minimum of 10 officers were selected from each ministry/agency or public
corporation. The ten (10) included Cabinet Ministers (or Managing Directors), Deputy
Ministers, Assistant Ministers and Directors of Departments. The message in this
approach is clear – LACC is interested in checking out the AD of all officers – NO
EXCEPTIONS.
LACC Assets [Declaration] Verification Report. 05.20.2013
Page 4
V.
Presentation of Detailed Findings
The AD Verification Team verified the assets disclosures of sixty-three (63) officials from
seven government institutions. The Institutions include:







Ministry of Finance
Ministry of Public Works
Ministry of Health and Social Welfare
Ministry of Internal Affairs
National Port Authority
Liberia Maritime Affairs
Liberia Anti-Corruption Commission
TOTAL
10
10
10
12
10
10
1
63
1. Findings
Based on the results of the interviews held, and the additional means of verification
adopted by the LACC team, the results are in 5 basic categories:
I.
Officials whose AD process was completed and for whom the LACC has joined
issues;
II.
Officials who deliberately decided not to cooperate with the LACC Team;
notwithstanding, LACC’s multiple notices to these individuals to appear. The AD
of these officials, for the above stated reason, could not be verified;
III.
Officials who sent in written excuses based on individual peculiar circumstances;
IV.
Officials whose AD process could not be completed within the timeframe, due to
outstanding issues still unresolved as at the time of report;
V.
Officials whose AD were verified and certified as truthfully declared.
LACC Assets [Declaration] Verification Report. 05.20.2013
Page 5
GROUP (I)
Officials whose AD process was completed and for whom the LACC has now joined issues:
1. Oretha Zeon
NPA
2. Matilda Parker
3. Blayon Brown Sarlee
NPA
MIA
4. Charles Gono
LiMA
Intentional and material misrepresentation;
unexplained wealth accumulation
Intentional misrepresentation
Intentional and material misrepresentation;
unexplained wealth accumulation
Unexplained wealth accumulation
1. ORETHA ZEON (NPA Port of Buchanan Operations Manager)
– intentional and material misrepresentation; unexplained wealth accumulation
CASE – Mrs. Oretha Zeon works as Operations Manager at the Buchanan Port. Mrs Zeon is on
a net salary of USD 840. She declared no other source of income. Mrs. Zeon declared [i.e.,
under oath] the value of a story building
[under construction] at US$15,000. However,
when the LACC’s AD Verification Team
doubted that a concrete storey building could
be valued at US$15,000, a revaluation was
ordered and funded by Mrs. Zeon and the selfsame house was revalued at US$51,200. This
is a clear indication of a glaring and
intentional misrepresentation of the facts
while under oath, which is in violation of the
Mrs Oretha Zeon US$15,000 (?) House 1
Laws of Liberia.
When asked for the source of income to fund the construction project, since her NPA salary
clearly cannot cover the project, Mrs. Zeon claimed that her children in the USA assist in the
process by sending her money regularly to finance the construction. When asked further to
provide evidence of banks transfer documents to substantiate her claims, Mrs. Zeon failed to
present the documents to the Team, noting that she started working long before members of
the LACC’s AD Verification Team were born.
This failure of Mrs. Oretha Zeon, NPA Operations Manager/Port of Buchanan, left the AD
Verification Team with no other conclusion but to find INTENTIONAL AND MATERIAL
MISREPRESENTATION [while under oath] and UNEXPLAINED WEALTH ACCUMULATION.
LACC Assets [Declaration] Verification Report. 05.20.2013
Page 6
2. MATILDA PARKER (NPA Managing Director/Chief Executive Officer)
– intentional and material misrepresentation
CASE – Ms. Matilda Parker is the Managing Director (CEO) of the National Port Authority
(NPA). Ms Parker embarked on a campaign of misrepresentation from the beginning of the
process to the end of the process. Ms Parker
purchased a house in the Sophie Community
Ms Parker US$65,000 House 1
SELLER contact address/details UNKNOWN
for US$65,000. However, when the LACC’s AD
Verification Team asked about the means of
payment, Ms. Parker said cash downpayment.
After the Team expressed surprise by a
US$65,000 cash downpayment, Ms Parker
later changed the story and said she made the
purchase in installments. Ms Parker was given
2 weeks to bring the receipts of the installment payments. She later wrote back that the
receipts were missing. The AD Verification Team asserts categorically, that both of the above
statements cannot be true at the same time – a cash downpayment of US$65,000 vs
installment payment of US$65,000. One of the two assertions is definitely false and Ms Parker
knows exactly which one is false.
Ms Parker was also asked to disclose the seller of the aforementioned Sophie Community
Property and the contact details of the seller. Ms Parker disclosed the name of the seller, but
declined to give any contact details (telephone, residential address and/or other means of
contact). This again is blatantly false information given to the LACC Team. No reasonable
person will pay a hefty US$65,000 for a property, but claims not to have any contact
information on the seller. This is clearly intentional and material misrepresentation and Ms
Parker must be held to account.
Ms Parker USA House: Ms Parker USA house was put at US$750,000 (2012) on her declaration.
When asked for documents on the mortgage, the house was discovered to be valued only
US$300,000 (2012). When asked to explain the gross disparity, Ms Parker said it was an error.
LACC AD Team wonders how a US$300,000 house can be erroneously valued at US$750,000.
Another one of Ms Parker’s intentional and material misrepresentations, even up to the very
end of the process. Ms Parker multiple misrepresentations [while under oath] left the Team
with no other option but to find intentional and material misrepresentation of the facts.
LACC Assets [Declaration] Verification Report. 05.20.2013
Page 7
3. BLAYON BROWN SARLEEE (Comptroller, Ministry of Internal Affairs)
– intentional and material misrepresentation; unexplained wealth accumulation
CASE – Mr. Blayon Brown Sarlee works as Comptroller, Ministry of Internal Affairs. He disclosed
a Gross salary of US$1,350. He disclosed no additional source of income, including the fact
that he has been a civil servant at MIA for more than a decade. Mr Brown Sarlee, as an
accountant, declined to disclose the value of his house(s) – in the space for value he wrote
N/A. The LACC AD Verification Team then requested an independent and objective appraisal
from Mr. Sarlee. He then disclosed his “objective” appraisal of the house (picture below) to be
US$45,000. LACC AD Team, suspicious of the appraisal, contacted the engineer. Mr. Sarlee’s
[contracted] engineer disclaimed the appraisal at LACC’s Office – noting that the appraisal was
done for banking purposes but NOT acceptable at all for LACC purpose.
Notwithstanding the aforesaid, Mr
Sarlee knows or should know that the
house picture aside cannot under
normal circumstances cost US$45,000.
This is a deliberate effort by Mr. Sarlee
to understate his assets so as to have
his assets commensurate with his
declared gross income of US$1,350.
This property is clearly 3-4X the value
declared by Mr. Sarlee. AD Verification
Mr. Brown Sarlee (MIA) US$45,000 (?) HOUSE 1
Team’s only logical conclusion on Mr. Brown Sarlee’s AD is intentional and material
misrepresentation of the facts [under oath]; unexplained wealth accumulation.
4. ATTY. CHARLES GONO, Deputy Commissioner, Marine Safety and Environment
– unexplained wealth accumulation
CASE – Atty Charles Gono, made a declaration on
his cash position. He also disclosed several concurrent work-in-progress construction projects,
which necessarily restricts his ability to save. Atty. Gono was asked to explain the cash deposit
of US$34,000 (in 3 installments) over a period of 2 months (June – August 2011) which
deposit is within the period under verification. Mr. Gono responded in writing that (1) My
salary being paid at ECOBANK and the bank workers were allegedly stealing from customers
accounts; hence I withdrew my salary and took it home…. (2) also I noticed my son was
stealing my money so I took it to International Bank Liberia Ltd.
LACC Assets [Declaration] Verification Report. 05.20.2013
Page 8
The AD Verification Team reviewed the above-mentioned ECOBANK salary account of Atty.
Gono and found that that account was never used to accumulate savings. It was basically
used as a conduit for the deposit of salary and the gradual withdrawal of salary. Accordingly,
this account, most certainly, could never have been the base from which Atty. Gono
accumulated the savings, from which he claimed the three-installment deposit of US$34,000 in
only 2 months in the IBLL account was made. This invalid and incorrect explanation led the
AD Verification Team to reasonably conclude unexplained wealth accumulation.
GROUP (II)
Officials who deliberately refused to cooperate with the LACC Team,
notwithstanding LACC’s multiple notices to these individuals to appear.
No AD verifications were conducted.
1. Sebastian Muah
Deputy Minister
2. Christian G. Herbert
Deputy Minister
3. Etweda Cooper
Supt. Grand Bassa Co
4. Victor Boye Smith
Deputy Minister
5. Abraham B. Samukai
Comptroller
6. Toagoe Karzon
Comptroller
7. Ernest Z. Coleman
Finance Officer/Ganta Hosp
8. Magaret Ansumana
Deputy Commissioner
9. Emmanuel N. Reeves
Deputy Commissioner
10. Jefferson ES Witherspoon Accounts Payable Manager
11. J. Tiah Nagbe
Deputy Minister
12. Ernest Gray Davis
Asst Supt Dev/Bomi Co.
13. John Z. Buway
Supt. Margibi Co.
14. Enson J. Amara
Accountant
15. Florence Dukuly
Deputy Minister
16. Victoria W. Duncan
Asst Supt Dev/Margibi Co.
17. Nathaniel Gbaba
Deputy Managing Director
18. Ernest Omaboe
Director of Security
GROUP (III)
MOF
MPW
MIA
MPW
MPW
MOH
MOH
LiMA
LiMA
LiMA
MIA
MIA
MIA
LiMA
MIA
MIA
NPA
LiMA
Officials’ whose AD process could not be completed within the reporting
timeframe, due to outstanding issues yet to be resolved:
1.
2.
3.
4.
5.
6.
7.
8.
Sam Foday Brown
Samuel Kofi Woods
Stephen M. Yekeson, Jr
Boom M. Wilson
Matthew TK Flomo
Varney Sirleaf
Blamo Nelson
Vivian T. Cherue
Supt. Bomi Co.
Minister
Deputy Minister
Comptroller-General
Deputy Minister
Deputy Minister
Minister
Deputy Minister
LACC Assets [Declaration] Verification Report. 05.20.2013
MIA
MPW
MPW
MOF
MOH
MIA
MIA
MOH
Page 9
GROUP (IV)
Officials who sent in written excuses based on each individual peculiar circumstance:
1. Ranney B Jackson
2. Neneh Kroyahn
3. Amara B. Konneh
Deputy Minister
Finance Manager
Minister
MIA
LiMA
MOF
GROUP (V)
Officials whose AD were verified and certified as truthfully declared:
1. Z. Adonie Greaves
2. Binyan Kessely
3. Desire S. Satia
4. Alexander Mitchell
5. Christiana K. Pawlay
6. Patrick M. Konneh
7. Joseph D. Wiles
8. Patrick B. Dunor
9. Wheazor Mulbah
10. Christopher B. Gray
11. Nyekeh Forkpah
12. William L. Slour
13. Andrew K. Kear
14. B. Wion Kanteah, Sr.
15. Bonar Kerkula
16. Joseph Y. Forkpah
17. Decontee King Sackie
18. James F. Kollie
19. Angela Cassell-Bush
20. Dede D. Sandiman
21. Juah K. Feika
22. Sebastian Weah
23. Jerry Taylor
24. Frances Johnson Allison
25. Walter T Gwenigale
26. Bernice Dahn
27. Ka-Rufus Morris
28. Annette Dennis Doe
29. Daniel D. Young
30. Zolia Y. Martor
Asst Supt for Development
Commissioner
Finance Director
Procurement Manager
Comptroller
Port Manager/Buchanan
Port Manager/Harper
Port Manager/Greenville
Procurement Manager
Deputy Managing Director
Assistant Minister
Assistant Minister
Procurement Director
Chief Accountant
Assistant Comptroller
Assistant Minister
Deputy Minister
Deputy Minister
Assistant Comptroller
Commissioner
Director
Director
Chairperson
Minister
Chief Medical Officer
Procurement Director
Chief Accountant
Hospital Administrator
Assistant Minister/Planning
LACC Assets [Declaration] Verification Report. 05.20.2013
MIA
LiMA
LiMA
LiMA
NPA
NPA
NPA
NPA
NPA
NPA
NPA
MPW
MPW
MPW
MPW
MPW
MOF
MOF
MOF
MOF
MOF
MOF
MOF
LACC
MOH
MOH
MOH
MOH
MOH
MOH
Page 10
VI.
Conclusions
The AD Verification exercise is one of the most important tools in the fight against
corruption. LACC takes this aspect of its mandate very seriously and will continue to
superintend the process of collection, storage, administration and verification. The
verification process is necessarily followed by sanctions for persons who choose to
misinform the LACC and lie under oath and for those caught with unexplained wealth.
The AD verification exercise is crucial in the prevention of corruption or in the curtailing
of corruption in our contemporary and globalized world. At the LACC, the AD process
was truly random and no particular individual or group of individuals were targeted.
The LACC set basic benchmarks based on the institution spending capacity or revenue
generating capacity.
The LACC notes, with dismay, the very high number of non-compliance (18/63 officials
– about 29% of invitees. These persons clearly have something to hide for deliberately
shying away from the AD exercise which has been sanctioned under the Act Creating
the LACC and publicly supported by the President. These are the kind of instances in
which stern examples would do lot of good to the image of the Government. Another
group of people that need to be sanctioned are those involved in unexplained wealth
accumulation (4/62 persons). This is equally reprehensible.
The LACC has done its work and the report is out. LACC calls on the Government, the
Public and the Press to do their part to ensure that the noted violators are sanctioned.
The LACC notes that the fight against graft and the systemic theft of public resources
should be the duty of each and every Liberian.
LACC Assets [Declaration] Verification Report. 05.20.2013
Page 11
VII.
Recommendations
Based on the three-month exercise, the AD Verification Team is pleased to note the
following recommendations:
1. That the LACC continues the AD Verification Exercise as same is in the interest of the
Nation and its people;
2. That the Government of Liberia provides the LACC with needed budgetary support
to ensure the continuation of and improvement of the exercise;
3. That appropriate administrative and/or legal actions be taken against those who (1)
disregarded the LACC AD Verification process, (2) those booked for unexplained
wealth accumulation, as well as (3) those caught making intentional and material
misrepresentation to the LACC;
4. That the LACC sets up a Division specifically responsible to do AD, since an ad-hoc
inter-departmental Team necessarily means divided attention, thus leading to lower
productivity.
5. That, in the interim, the LACC moves to ensure the security of the AD forms, given
that the current verification process has ostensibly raised the stakes.
LACC Assets [Declaration] Verification Report. 05.20.2013
Page 12
LACC Assets [Declaration] Verification Report. 05.20.2013
Page 13
LACC Assets [Declaration] Verification Report. 05.20.2013
Page 14