This chapter examines key elements of the conflict-of-interest management framework, including gift and gratuity management, pre- and post-public employment, and interest and asset declarations, and proposes recommendations to strengthen the regulatory framework and their implementation in practice to effectively achieve both its prevention and detection purposes. The first section focuses on interest declarations, gifts and gratuities, and pre- and post-public employment, while the second section reviews the asset declaration system under the responsibility of the Chamber of Accounts of the Dominican Republic.
OECD Integrity Review of the Dominican Republic
Implementing a Strategic Vision for Public Integrity and Anti-Corruption
Abstract
Public integrity refers to the “consistent alignment of, and adherence to, shared ethical values, principles and norms for upholding and prioritising the public interest over private interests in the public sector” (OECD, 2017[1]). In other words, it involves doing the right thing, for the right reasons and in the right way (Heywood et al., 2017[2]). Understanding what is meant by “right” requires setting clear integrity standards. Governments can set high standards of conduct through the legal framework, which helps to clarify what conduct is expected of public officials (OECD, 2020[3]). Governments can safeguard standards through proportionate procedures to prevent and manage issues that could undermine public integrity standards (such as conflict of interest), for example through awareness raising and capacity-building, and effective enforcement. Establishing standards of conduct that can be learned, internalised and enforced can support the development of a shared understanding across the public sector and among citizens.
The OECD Recommendation on Public Integrity calls on adherents to set high standards of conduct for public officials through a number of actions, including (OECD, 2017[1]):
Going beyond minimum requirements, prioritising the public interest, adherence to public-service values, an open culture that facilitates and rewards organisational learning and encourages good governance
Including integrity standards in the legal system and organisational policies (such as codes of conduct or codes of ethics) to clarify expectations and serve as a basis for disciplinary, administrative, civil and/or criminal investigation and sanctions, as appropriate
Setting clear and proportionate procedures to help prevent violations of public integrity standards and to manage real or potential conflict of interest
Communicating public sector values and standards internally in public sector organisations and externally to the private sector, civil society and individuals, and asking these partners to respect those values and standards in their interactions with public officials (see Chapter 3).
In particular, conflict of interest is an area where clear standards, guidelines and procedures are key for maintaining integrity in the performance of public activities by public officials. While it is normal that the private interests of public officials may compete with the general interest, it is imperative that their private interests do not unduly, or be seen to influence, the performance of their official duties and responsibilities (OECD, 2004[4]). Prioritising the public duty over personal interest ensures that public policies are designed and implemented in a fair and unbiased way, and can strengthen the public’s trust in its policymakers, as well as the legitimacy and credibility of public policies (OECD, 2020[3]).
At the same time, managing conflict of interest is one of the key areas of public integrity systems where countries face the greatest difficulty to translate regulations into practice. The OECD’s Public Integrity Indicators show that countries fulfil an average 85% of criteria on the strength of conflict-of-interest regulations but only 42% of criteria on practice, leaving an implementation gap of 43 percentage points (OECD, 2026[5]). Such a gap may stem from various factors, including insufficient verification of declarations, a lack of guidance from public authorities on resolving conflict of interest, and failure to submit declarations in practice (OECD, 2026[5]).
The Dominican Republic has made progress in establishing integrity standards and procedures for its public officials (see also Chapter 1). Table 2.1 summarises the most relevant laws and decrees that establish standards of conduct on conflict-of-interest management for public officials, including the Public Service Law (Ley de Función Pública, No. 41-2008) and its Regulatory Decree No. 523-2009.
Source: OECD authors’ elaboration.
As measured by the OECD Public Integrity Indicators, the Dominican Republic fulfils 78% of criteria on conflict-of-interest regulations, reflecting ongoing efforts to set a coherent regulatory framework, while still pointing to areas for further reform. Moreover, similarly to the global situation, there is an implementation gap of 56 percentage points, demonstrating more efforts are needed to strengthen awareness of the standards, knowledge on how to manage conflict of interest, and commitment to manage them in practice (Figure 2.1).
Note: 2025 data or latest year available.
Source: OECD Public Integrity Indicators Database (data extracted on 7 March 2026), https://oecd-public-integrity-indicators.org/.
The Constitution, Law No. 41-2008, and Decree No. 523-2009 establish incompatibilities for public functions and other activities. However, neither the legal or regulatory framework define circumstances and relationships that can lead to conflict-of-interest situations for public officials nor establish specific obligations for the management or resolution of conflict-of-interest situations (see Table 2.2). Moreover, although the Dominican Republic has regulations that require high-level public officials from the Government, members of the National Congress (Congreso Nacional) and members of the highest bodies of the judiciary to submit interest declarations upon assuming office, changing position, or when there is a change in their situation, these disclosures are integrated into the asset declaration system, only covering financial information. As a result, they are primarily used for the verification of unjustified wealth and the detection of illicit enrichment, rather than as a preventive tool for identifying and managing potential conflict of interest.
Source: OECD Public Integrity Indicators Database (as of 10 March 2026), https://oecd-public-integrity-indicators.org/.
In practice, submission and verification rates remain low, limiting the effectiveness of the conflict-of-interest framework. For instance, while there is a risk-based approach to verifying declarations, since 2018, only 14% of submitted declarations have been verified by the responsible authority, demonstrating that oversight mechanisms need to be further strengthened (OECD, 2026[6]). Moreover, there is no available information on sanctions imposed for non-compliance with disclosure obligations, non-management or non-resolution of a conflict-of-interest situation (see Table 2.3).
Source: OECD Public Integrity Indicators Database (as of 10 March 2026), https://oecd-public-integrity-indicators.org/.
In light of these findings, this chapter further unpacks key elements of the conflict-of-interest management framework, including gift and gratuity management, pre- and post-public employment, and interest and asset declarations, and proposes actions to close regulatory gaps, as well as ensure the respective tools fulfil their prevention purpose.
In the Dominican Republic, the legal framework includes certain prohibitions applicable to public officials of the State, municipalities and autonomous entities, aimed at preventing conflict of interest. First, Law No. 41-2008 (Articles 79 and 80) establishes duties and prohibitions in relation to situations that may lead to conflict of interest. In particular, Article 79 stipulates that it is the duty of public officials “to act impartially in the performance of their duties by giving equal treatment and service to whom the law so indicates...” and “to maintain the discretion and confidentiality required by matters related to their work, (...), even after they have left office” (Government of the Dominican Republic, 2008[7]). Among others, Article 80 prohibits public officials from “participating in official activities that deal with subjects in which the public official has particular economic, asset-related or political interests that in some way pose a conflict of interest”, “serving in the same institution as his or her spouse and those related by blood or affinity up to and including the second degree, when they have a hierarchical relationship” and “acting in cases where they have particular interests that pose conflicts of interest for the public official” (Government of the Dominican Republic, 2008[7]).
Second, Law No. 105-2013 establishes incompatibilities and prohibitions related to the salaries and remuneration of public officials. Specifically, Articles 24 and 25 prohibit, among other things, receiving remuneration from the State other than that pertaining to their job; performing additional roles that involve the payment of benefits and remuneration from other sources except for teaching activities; using their position to obtain advantages, benefits or privileges that are not permitted by law, directly or indirectly, for themselves or for a member of their family or any other person, business or entity; and promoting and fostering nepotism in state offices.
In addition, the Dominican Republic has established specific incompatibilities in the area of public procurement and contracting. Recently, Law No. 47-2025 on Public Procurement, which repeals Law No. 340-2006, redefines and expands who may not be bidders or enter into a contract with the State. The Law establishes “absolute” disqualifications (prohibiting contracting under any circumstances) and “relative” disqualifications (prohibiting contracting with a specific institution); it disqualifies legal entities whose ultimate beneficiaries are disqualified; extends the periods of disqualification for criminal convictions or agreements in which liability for offenses is admitted; prohibits the contracting of legal entities with participation from public officials or their relatives, regardless of the percentage of such participation; among other provisions.
However, these provisions focus mainly on prohibiting specific and predefined conflict-of-interest situations, without recognising that conflict of interest is an inherent, and in many cases unavoidable, part of holding public office. International good practice stresses that the existence of different types of conflict of interest –real, potential and apparent– requires differentiated policies and responses that go beyond a purely prohibitive approach. For example, the mere existence of a potential conflict of interest does not necessarily constitute an indication of corruption or misconduct, but requires transparent, preventive and proactive management (OECD, 2004[4]; World Bank/OECD/UNODC, 2020[8]).
To move beyond a prohibition-based approach, the Dominican Republic could consider establishing a conflict-of-interest management system that prioritises prevention through early identification, disclosure and implementation of proportionate mitigation measures. The Draft Organic Law prepared by the Directorate General of Ethics and Government Integrity (Dirección General de Ética e Integridad Gubernamental, DIGEIG) to establish the Directorate of Integrity, Transparency and Government Ethics (Dirección de Integridad, Transparencia y Ética Gubernamental, DIGITEG) (see also Chapter 1), includes a provision that would strengthen conflict-of-interest management through a dedicated subsystem. Once adopted, this subsystem could be developed in line with the recommendations below, with the aim of establishing a comprehensive framework for the identification and management of conflict of interest across the public sector. At a minimum, it could include the following elements:
The obligation of public officials to actively manage conflict of interest, accompanied by guidance on the measures available for their proper management
Clear and uniform definitions of key concepts, such as real, apparent and potential conflict of interest, and private interest (both financial and non-financial)
An obligation of public officials to declare their private interests, together with clear and proportionate procedures for complying with this obligation
The designation of a body or unit responsible for providing guidance on what constitutes a conflict of interest, how to identify it and how to manage it
Clear responsibilities for monitoring and enforcing conflict-of-interest rules
An effective, dissuasive and proportionate system of sanctions for non-compliance.
2.2.1. The Dominical Republic could clearly define key concepts such as real, potential and perceived conflict of interest, and private interest
Clear, precise and realistic definitions of the circumstances and relationships that may give rise to a conflict of interest are essential to avoid misinterpretation and to enable public officials to properly identify and manage such situations. In general terms, a “conflict of interest” is defined as “a conflict between the public duty and the private interest of a public official, in which the official’s private-capacity interest could improperly influence the performance of their official duties and responsibilities” (OECD, 2004[4]).
Two complementary concepts are essential to properly understand and address conflict of interest: (i) the distinction between real, potential and perceived conflict of interest, and (ii) the notion of private interest. In relation to the first concept, differentiating between these three types of conflict of interest is essential to develop specific policies and responses that respect integrity standards without imposing unnecessary restrictions on public officials. For example, while a real conflict of interest requires immediate intervention to prevent misconduct and safeguard the integrity of the public service, a potential conflict of interest allows for preventive action to be taken before misconduct materialises. Similarly, the identification and management of perceived conflict of interest is essential to preserve public confidence, as even a reasonable perception of bias can undermine institutional credibility, even in the absence of wrongdoing.
In this regard, the Dominican Republic could establish in its regulatory framework a definition of “conflict of interest” that expressly distinguishes between real, potential and perceived conflict of interest. Examples from other countries and international standards could serve as inspiration (Box 2.1).
The OECD Guidelines on Managing Conflict of Interest in the Public Sector distinguish between three types of conflict of interest: real (or actual), potential and perceived (or apparent):
A real conflict of interest exists when there is a conflict between the public duty and private interests of a public official, in which the public official has private-capacity interests which could improperly influence the performance of their official duties and responsibilities.
By contrast, a perceived conflict of interest can be said to exist where it appears that a public official's private interests could improperly influence the performance of their duties, but this is not in fact the case.
A potential conflict of interest arises where a public official holds a private interest which would constitute a conflict of interest if the relevant circumstances were to change in the future.
The Directive on Conflict of Interest of Canada provides direction to persons employed and designated senior officials to enable them to minimise risks associated with real, apparent and potential conflict of interest and conflict of duties situations with the goal of upholding the values and ethics of the public sector and the public interest. To help Canadian public servants understand the meaning and importance of the three types of conflict of interest, the Government of Canada published the “Apparent conflict of interest” guidelines, which provides definitions to distinguish between the three types of conflict of interest:
A real conflict of interest refers to a situation in which a public official has knowledge of a private economic interest that is sufficient to influence the performance of their official duties and responsibilities.
A potential conflict of interest incorporates the concept of foreseeability: when a person can foresee that a private interest may someday be sufficient to influence the performance of their duties, but has not yet, they have a potential conflict of interest.
An apparent conflict of interest exists when there is a reasonable apprehension –which a reasonably well-informed person could properly have– that a conflict of interest exists.
Regarding the second concept, private interests are not limited to financial or pecuniary interests, nor exclusively to those that generate a direct personal benefit for the public official. Conflict of interest may also arise from legitimate private-capacity activity, such as personal affiliations, professional associations, family ties or social commitments, that could reasonably be considered likely to influence improperly the official’s performance of their duties (OECD, 2004[4]).
To strengthen understanding and awareness of the diversity of private interests that may give rise to a conflict of interest, the Dominican Republic could complement the definition of “conflict of interest” with a broad definition of “private interest” that includes both financial and non-financial interests. The Dominican Republic could also consider developing practical guidelines to accompany the proposed legislation by adding a non-exhaustive list of examples of relevant interests –such as personal affiliations and associations, family interests and outside activities– in order to facilitate their identification by public officials (see Box 2.2).
OECD countries have identified the following types of external activities and positions to be potential conflict of interest risk factors:
Assets
Liabilities and debts
Personal relations
Family relations
Commercial interests
Gifts, benefits and hospitality
Outside activities and positions in voluntary organisations
Outside activities and positions in NGOs
Outside activities and positions in elected public bodies
Outside activities and positions in trade unions
Outside activities and positions in a political party
Secondary employment in the public sector
Outside activities and positions in an entity with government relations
Private sector positions
Secondary employment in the private sector
Source: (OECD, 2004[4]).
2.2.2. The Dominican Republic could establish specific obligations for public officials to declare their private interests and manage their conflict of interest, as well as clear procedures for such purposes
A comprehensive conflict-of-interest management system should, as a starting point, encourage public officials to identify and disclose in a timely manner relevant private interests that may lead to conflict with the performance of their public duties (OECD, 2004[4]). To this end, it is essential to have clear, accessible and proportionate provisions and procedures that reinforce the individual responsibility of public officials to identify and declare any relevant information related to a conflict of interest –real, potential or perceived– both upon entering public office (initial declaration) and subsequently, when changes in their personal or professional circumstances occur during their tenure (OECD, 2004[4]).
Moreover, the proactive declaration of private interests not only contributes to the prevention of a conflict of interest, but also protects public officials from situations that could affect their personal or professional reputation, or undermine public confidence in a government programme or policy.
In addition to a general obligation for all public officials to identify and manage their conflict-of-interest situations, the Dominican Republic could also consider establishing a specific obligation for at-risk public officials to declare private interests that may give rise to a real, potential or perceived conflict of interest: (i) upon entry into the position, and annually thereafter, (ii) any renewal or change in position, or (iii) at the first subsequent opportunity when they become aware of a conflict of interest in the performance of their duties. For the initial declaration, a deadline of up to 30 days from the beginning of the term of office could be considered, in order to harmonise this requirement with the current deadline for submitting the asset declaration (see next section).
Additionally, the regulations should clearly establish the bodies to which declarations of interests must be submitted, as well as the responsibilities of these bodies in terms of reviewing, analysing and verifying the information, to support public officials in identifying possible situations of conflict of interest and applying appropriate mitigation measures. A differentiated approach based on the level of risk could be adopted. In the executive branch, high-level public officials (including politically exposed persons), administrative and financial directors, procurement and contracting officers, and other public officials in higher risk positions could declare their interests to the DIGEIG, while all other public officials could submit their declarations to the human resources offices of their respective institutions.
To further support transparency and accountability, the Dominican Republic could consider introducing an obligation to publish select elements of the interest declarations of high-level public officials and those in at-risk positions. Personal data, including the declarant’s personal information and that of their family members, among others, should be excluded. This would help strike an appropriate balance between transparency and the protection of individual privacy.
However, disclosure of a private interest alone does not resolve a conflict of interest, rather it is the starting point for determining the actions necessary to resolve or manage it appropriately (OECD, 2004[4]). To that end, clearly defining appropriate mitigation measures can help move from a simple compliance exercise to actively managing potential conflict-of-interest situations.
The Dominican Republic could therefore establish an express obligation for all public officials to actively manage conflict of interest in the regulatory framework, followed by guidelines with clarity on the possible mitigation measures to apply, according to the nature and seriousness of the case. These measures could include both options aimed at eliminating or mitigating the influence of a private interest, as well as mechanisms aimed at limiting the participation of the public official with a conflict of interest in certain decision-making processes, in accordance with international good practices (see Box 2.3).
To facilitate the implementation of this obligation, public officials could be required to propose concrete mitigation actions in an ad hoc declaration of interest form, which should be evaluated, validated and followed up by a competent body. For the executive branch, these responsibilities could be assumed by the DIGEIG for high-level officials and human resources offices for public officials in general.
Where a public official has a potential or real conflict of interest, there are a number of steps that can be taken to manage the conflict and reduce the risk of improper influence. These measures can be classified into “strategies that focus on the private interest” and “strategies that focus on the public official”.
Strategies that focus on the private interest seek to eliminate or mitigate the influence that a private interest can exert on a public official and include:
Divestment: the public official completely renounces their outside interest, for example, by selling stocks or shares. Transferring the private interest to a family member does not amount to divestment.
Resignation: the public official resigns from the outside employment position that is causing the conflict of interest.
Waiver of rights: the public official renounces all involvement in specific activities of their outside employment that could lead to a conflict of interest.
Establishment of a 'blind trust' arrangement to manage the financial interests (e.g. stocks, shares or other investments) of the public official while holding public office. The interests are transferred to a third party, who manages them independently. The public official remains the beneficiary, but cannot interfere in the management of the assets, give instructions or know how the assets are invested/used.
Strategies that focus on limiting the influence of the public official on the decision-making process include:
Recusal or restriction: Where a particular conflict is not likely to recur frequently, it may be appropriate for the public official concerned to maintain their current position but not participate in decision-making on the affected matters, for example by having an affected decision made by an independent third party, or by abstaining from voting on decisions. Particular care must be exercised to protect the integrity of the decision-making process where recusal is adopted.
Similarly, another option could be to restrict the access of the public official concerned to private information, prohibiting them from receiving relevant documents and other information relating to their private interest.
Reassignment: the public official is reassigned to a different set of duties, tasks or portfolios.
Resignation: In some cases, the conflict of interest may be so difficult to manage, and the potential negative consequences so severe, that resignation or removal from office may be the only viable strategy to maintain public trust. In the event that the public official resigns from public office, the conflict-of-interest policy (together with the relevant employment law and/or employment contract provisions) must stipulate the possibility of removing the public official from office pursuant to a set procedure in such circumstances.
To support public officials –both general and at-risk– in their reporting obligations, two reporting forms could be developed by the DIGEIG: (i) a declaration of interests form upon taking up a new position that is updated annually, and (ii) an ad hoc declaration of interest form for specific situations that arise during the term of office.
The initial declaration form could include, among other aspects: (a) information on public and private activities during the previous year; (b) relevant family ties; and (c) information on outside activities, paid or unpaid.
The ad hoc declaration form could include: (a) a description of the private interest(s) that impact the public official's specific public duty; (b) a description of the public duty affected; (c) the type of conflict-of-interest situation (real, potential or perceived); and (d) a signed declaration by the public official whereby they undertake to appropriately manage the conflict-of-interest situation.
2.2.3. The Dominican Republic could define clear institutional responsibilities for the conflict-of-interest management system, including roles for providing advice and guidance, and monitoring and verification
A comprehensive conflict-of-interest management system requires not only clear disclosure obligations, but also clarity in terms of institutional responsibilities for management, including monitoring and verification, the provision of advice and guidance, and enforcement (OECD, 2004[4]).
As conflict-of-interest management is a developing area in the Dominican Republic, ensuring that public officials have the support and guidance to manage conflict of interest is essential. To that end, accessible, reliable and secure channels can be established to enable public officials to raise ethical issues and dilemmas related to their private interests in an environment of trust. This creates a double benefit: on the one hand, it helps to prevent conflict-of-interest situations before they arise; on the other hand, it strengthens the ethical awareness and capacity of public officials to apply integrity standards in the day-to-day performance of their duties.
The Dominican Republic could therefore assign responsibility for providing advice and guidance on potential conflict-of-interest situations, completion of interests forms and mitigation measures within the executive branch to the Government Integrity and Regulatory Compliance Commissions (Comisiones de Integridad Gubernamental y Cumplimiento Normativo, CIGCN) in the respective institution (see also Chapter 1). For the Legislative and Judicial branches, a dedicated contact point could be set up, with responsibilities for receiving queries when questions arise about a possible conflict of interest, providing specialised guidance on the matter and supporting public officials in the proper completion of the declaration of interests forms.
To complement the advisory services, the Dominican Republic could also consider developing practical guides that give concrete examples, relevant to public officials’ daily work, of the standards of conduct set out in the new conflict-of-interest legislation. In this regard, the DIGEIG could consider developing guidelines and toolkits in order to support the understanding and enforcement of the standards of conduct set out in the new conflict-of-interest legislation. Examples from other countries could serve as inspiration for the DIGEIG (Box 2.4). Regarding its development, the DIGEIG could collaborate with relevant entities such as the Directorate General of Public Procurement (Dirección Nacional de Contrataciones Públicas) and the Office of the Comptroller General of the Republic (Contraloría General de la República), which have information on the risks associated with key processes. The DIGEIG could also gather general feedback from the CIGCN on the most frequently asked questions in order to proactively address recurring issues in the practical guides, without discussing the details of specific questions or individual cases.
In Costa Rica:
The Judiciary developed a toolkit with various resources to support awareness-raising and management of conflict of interest. This toolkit includes a conflict-of-interest simulator, explanatory videos and infographics on the Regulation for the “Prevention, Identification and Management of Conflict of Interest in the Judiciary”, as well as examples of conflict-of-interest situations that may arise, and relevant manuals and circulars that further develop the conflict-of-interest regulations.
The Attorney for Public Ethics (Procuraduria de la Ética Pública, PEP) developed a series of basic guides and manuals to prevent and combat corruption, including a Basic Guide to Preventing, Identifying and Managing Conflicts of Interest in the Public Sector. This guide provides practical guidance for the proper prevention, identification and management of conflict of interest, through the introduction of key concepts, illustrative examples and explanations of applicable law.
In France, the High Authority for Transparency in Public Life (Haute Autorité pour la Transparence de la Vie Publique, HATVP) is responsible for overseeing the integrity of public officials, ensuring compliance with their ethical obligations and preventing conflict of interest. This includes, among others, receiving and verifying the asset and interest declarations of public officials (both elected officials and career civil servants), including members of the government, deputies and senators, advisors to the President of the Republic, ministers, and the presidents of the National Assembly and the Senate.
Since the concepts of “conflict of interest” and the act of unlawfully accepting or taking a benefit can be difficult to assess, the HATVP published two comprehensive conflict-of-interest guides for public organisations, officials and ethics officers. These guides present the High Authority's doctrine on conflict-of-interest risks and provide a summary of the ethical procedures that mark the career of a public official.
Note: To see the HATVP guides: Ethics Guide Handbook for Public Managers and Ethics Officers https://www.hatvp.fr/wordpress/wp-content/uploads/2019/04/HATVP_guidedeontoWEB.pdf and Ethics Guide II Control and Prevention of Conflicts of Interest https://www.hatvp.fr/wordpress/wp-content/uploads/2021/02/HATVP_GuideDeontologie_2021_A-Imprimer.pdf
Sources: (OECD, 2022[10])
Beyond access to advice and guidance, effective conflict-of-interest management requires clear responsibilities for monitoring and verification. Such responsibilities ensure that conflict-of-interest management is not only a paper-exercise, but a living integrity function that safeguards the public interest. To that end, the same units and bodies responsible for receiving interest declarations could also be tasked with monitoring reporting obligations and verifying the content of the declarations. In the executive branch, this corresponds to human resource management units and the DIGEIG, for high level officials. Verification of interest declarations should follow a risk-based approach rather than requiring the systematic review of every declaration. This could include prioritising declarations submitted by officials in higher-risk positions, declarations that present potential red flags or inconsistencies, and cases identified through complaints or other credible information. The DIGEIG could develop a methodology, including criteria for selecting interest declarations for review, to ensure a consistent and transparent approach across the executive branch. Where non-compliance is identified, these bodies or units should report cases to the appropriate bodies for investigation.
Beyond the core responsibility for supporting public officials in upholding the public interest through effective conflict-of-interest management, these bodies can also contribute to the effective management of the integrity system. In doing so, the bodies should have in place systems to collect and systematise up-to date and reliable information on the number of declarations submitted annually, by category of public official, data on the number of ad hoc declarations, as well as information on the ethical queries received, types of mitigation measures recommended and implemented, and cases referred to investigative bodies due to failure to disclose or non-compliance with obligations. Appropriate data protection and security measures should be in place to protect confidentiality and avoid damaging breaches. The information should be analysed periodically to identify areas for improvement, propose reforms and strengthen the preventive tasks of the system for identifying and managing conflict of interest.
2.2.4. The Dominican Republic could ensure that sanctions for breaches of the conflict-of-interest obligations are defined and clear responsibilities for investigation and enforcement are established
A well-functioning conflict of interest system requires a clear distinction between preventive guidance and enforcement functions, alongside a robust framework for accountability. In principle, advisory and preventive functions should be institutionally and operationally separated from investigative and sanctioning functions. Such separation helps maintain trust the advisory system by ensuring that public officials can seek guidance on potential conflicts of interest without fearing that doing so will automatically trigger an investigation or disciplinary action. At the same time, effective enforcement remains essential to uphold the integrity of the system by ensuring that breaches are detected, investigated and, where appropriate, sanctioned through measures that are effective, proportionate and dissuasive (World Bank/OECD/UNODC, 2020[8]).
In practice, complete institutional separation may not always be feasible, particularly where specialised expertise and limited administrative resources favour concentrating responsibilities within a single institution (see also Chapter 1). This appears to be the case in the Dominican Republic, where the DIGEIG is well placed to develop expertise in both preventing and addressing conflict of interest. However, where advisory and enforcement functions coexist within the same institution, it is important to establish clear functional separation and procedural safeguards. In particular, public officials responsible for providing advice and guidelines should be distinct from those responsible for investigations and disciplinary proceedings, with appropriate information barriers, documented procedures and separate reporting lines.
Within the executive branch, human resources units could play a first-line role when it comes to conflict of interest of general public officials and referring them to the DIGEIG, while the DIGEIG could be responsible for conducting investigations and, where appropriate, referring cases to the competent disciplinary or judicial authorities for sanction. Similarly, the Legislative and Judicial branches should ensure that they each designate or establish a competent body with the authority to investigate alleged breaches of the conflict-of-interest framework and initiate or recommend appropriate disciplinary or sanctioning measures, while maintaining a clear functional separation between advisory and enforcement responsibilities.
The Dominican Republic could also implement a system of sanctions that meets the criteria of effectiveness, dissuasiveness and proportionality, including clear sanctions linked to the different requirements of the conflict-of-interest management system. For example, sanctions could be foreseen for: failure to submit the initial declaration of interest in a timely manner; false declaration of information; failure to disclose an ad hoc conflict of interest; failure to resolve a conflict of interest; accepting or exercising a prohibited private interest or position; or acting in situations of real or perceived conflict of interest, among others. This could include disciplinary, administrative or criminal sanctions, or a combination of such. A system that provides for a diverse range of sanctions facilitates the enforcement of measures proportionate to the misconduct (World Bank/OECD/UNODC, 2020[8]). A system that only considers criminal sanctions could limit action to the most serious offences, leaving other conduct uncovered which, although less obvious, also affects the public interest and public trust.
2.2.5. The Dominican Republic could establish measures to mitigate integrity risks and manage conflict of interest on pre- and post-public employment in the legislation
A conflict of interest can arise from the so-called “revolving door phenomenon”, i.e. movement between the public and private sectors. While this exchange can generate positive effects –notably the transfer of knowledge, technical know-how and expertise– it can also lead to improper or unfair advantages in influencing public policy and decisions when it is not properly regulated and managed (OECD, 2021[11]). For example, public officials coming from the private sector might make decisions that favour the companies or sectors they come from, or, conversely, private companies might offer appealing job opportunities to public officials in return for undue favours.
To mitigate these risks, governments need to establish rules and procedures for entering the public sector from the private sector and vice versa, and for detecting and addressing such situations in a timely manner. When designing these measures, it is essential to identify an appropriate balance between restrictions and incentives: on the one hand, limitations on movement between the two sectors should protect the integrity of public processes and prevent abuse; on the other hand, they should not prevent the public sector from attracting and retaining the talent necessary for the effective performance of its duties.
Currently, the Dominican Republic’s framework, through Law No. 41-2008, includes minimal safeguards for pre- and post-public employment integrity. These include Article 79, which sets out confidentiality requirements after leaving public office, and Article 80, which prohibits public officials from participating in official activities which have a particular economic (amongst other) interest that could pose a conflict of interest. However, as a whole, the legal framework lacks provisions that comprehensively regulate the risks linked to interaction with the private sector in situations of pre- and post-public employment, and there is no supplement guidance to help officials manage potential pre- and post-public employment risks. Beyond this regulatory gap, the absence of institutional procedures aimed at identifying and managing these situations in a timely manner also undermines effective management of such risks.
The Dominican Republic could therefore strengthen the regulatory framework by including measures aimed at identifying and managing conflict-of-interest situations before and after holding public office. Such measures could include:
Measures to mitigate risks arising from employment prior to holding public office, aimed at protecting the integrity of recruitment processes for persons from the private sector. In addition to interest disclosure, as discussed above, these measures could also include temporary restrictions on the performance of certain duties after taking up public office, the provision of specific ethics guidance for new public officials (see Chapter 3), as well as pre-recruitment integrity checks. Comparable measures have been implemented in countries such as Australia and France (Box 2.5) and could serve as inspiration for the Dominican Republic.
Measures to mitigate risks arising from post-public employment, aimed at protecting government processes against possible improper influence following the departure of public officials from office. Such measures could include, for example, “cooling off” periods during which certain activities, such as lobbying or representing interests before public bodies, are restricted. As detailed in the Anti-Corruption and Integrity Outlook 2026 (OECD, 2026[5]), similar experiences exist in several OECD Member and partner countries (Table 2.4).
Integrity and reliability checks in Australia
In Australia, each public entity must carry out a check to ensure the eligibility and suitability of its personnel who have access to government resources prior to an offer of employment or contract.
The Protective Security Policy Framework (PSPF), Australia’s whole-of-government policy on protective security matters, requires that the eligibility and suitability of personnel who have access to Australian Government people and resources is ensured. The following are mandatory pre-employment checks:
Identity check: helps to establish confidence in a person’s identity and provides entities with a level of assurance about the prospective employee.
Eligibility Check: confirms whether a person is eligible to work in Australia. This requires confirmation that a person holds Australian Citizenship, or if the person is not an Australian citizen, confirming that they have a valid work visa.
While verification of personal identity and eligibility to work in the country is mandatory, integrity and reliability checks are also recommended, which include the following:
Employment history check: identifies if there are unexplained gaps or anomalies in employment.
Residential history check: helps to confirm the identity of the person within the community. All personnel must provide supporting evidence of their current permanent home address.
Employment reference check: helps entities appoint individuals who meet the necessary standards of competence, suitability, and integrity. It is recommended that professional reference checks cover at least the previous 3 months. A reference check may address: 1) any substantiated complaint about the person's behaviour; 2) information about any action, investigation or enquiry relating to the person's character, competence or conduct; 3) any security-related factor relevant to the person's integrity and reliability.
National Police check: commonly known as a criminal history check or police records check, this involves processing a person's biographical data (such as name and date of birth) to determine if it matches that of anyone with a criminal record.
Credit history check: A credit history check establishes whether the person has a history of financial defaults, is in a difficult financial situation, or if there are concerns about their finances.
In addition, the Department of Home Affairs recommends that entities identify the controls necessary to mitigate any additional risks that are not covered by the recommended minimum controls. Examples include drug and alcohol testing, detailed financial probity checks and psychological assessments.
Restrictions on taking up a post in the French public administration
In France, different types of compatibility checks apply at different stages of a public official’s career.
First, before an appointment, the High Authority for Transparency in Public Life (HATVP) may be required to assess whether a candidate who has worked in the private sector during the previous three years can be appointed to certain public positions. Since the Public Sector Transformation Law of 6 August 2019, the HATVP is mandated to carry out this “pre-appointment” check for the following positions:
Director of a central administration and head of a public entity whose appointment is subject to a decree by the Council of Ministers.
Director General of services in regions, departments or municipalities with over 40 000 inhabitants and in public establishments of inter-municipal co-operation which have their own tax system and with a population of over 40 000 inhabitants.
Director of a public hospital with a budget of over EUR 200 million.
Member of a ministerial cabinet.
Collaborator of the President of the Republic.
Second, during the performance of public duties, the HATVP may examine requests from public officials wishing to create or acquire a private business while continuing to perform their public functions on a part-time basis. All public servants have to ask for the authorisation of such an activity, and part of them will depend on the direct jurisdiction of the High Authority.
Finally, after leaving public office, the HATVP reviews situations in which former public officials intend to take up a private activity within three years of leaving office.
Article 432-13 of the Criminal Code applies to civil servants who find themselves in a conflict-of-interest situation after leaving public office. For a period of three years after the end of their previous employment, they cannot be entrusted with the oversight or control of a private undertaking or with entering into or giving an opinion on contracts of any kind with a private undertaking. They are also prohibited from proposing decisions on the operations of a private enterprise and from giving opinions on such decisions. They should not receive advice from, or acquire ownership interests in, such enterprise. Any violation of this article is punishable by three years' imprisonment and a fine of EUR 200 000.
How to read: In Greece, post-employment integrity is not tracked for ministers or for top-officials. There are regulations stating mandatory cooling-off periods for public officials.
Note: In France, the High Authority for Transparency in Public Life (HATVP) does not have the means to collect information on the movement of ministers into sectors they formerly regulated, but movement is managed as part of the revolving doors control exercised by the HATVP. In Finland, while some ministries track movement, not all do and the value is “not tracking”.
Source: OECD Public Integrity Indicators database (as of 10 March 2026), https://oecd-public-integrity-indicators.org/.
In defining and implementing these measures, an appropriate balance between restrictions and incentives should be sought, based on a risk analysis. For example, prohibitions on lobbying after holding public office may be relevant for a limited period (see Chapter 8), while restrictions on the use or disclosure of inside information may remain in place until such information becomes public or loses its sensitive nature.
Moreover, in terms of application, care should be taken to avoid a blanket requirement for all public officials. Instead, informed by a risk-based approach, the pre- and post-public employment measures could be applied to elected and appointed public officials, advisors, senior officials, as well as those who have frequent contact with private sector representatives, such as those involved in public procurement, regulatory policy, inspections, tax collection and customs.
In addition to clarifying the obligations and scope of the measures, the Dominican Republic could introduce an obligation for public officials to declare information regarding their post-employment activities, both before leaving office and for a period thereafter, to a responsible body, for example the bodies or units in charge of receiving, analysing and verifying declarations of interests in each of the branches of government (see previous section). The declaration duration should be commensurate with the level of risk associated with the position held. This type of system has been implemented in several countries, such as Spain, under Law No. 3-2015 (Box 2.6). The information contained in these declarations would serve as a baseline for oversight work, allowing the responsible bodies or units to subsequently cross-check it with information from other sources, such as tax and labour authorities' registers and databases, in order to detect possible non-compliance or undisclosed conflict-of-interest situations.
High-level public officials must apply for authorisation to engage in professional activities after leaving office. Article 15 of Law No. 3-2015, regulating the exercise of high-level positions in the General State Administration, prohibits senior officials from providing services to private entities that have been affected by decisions in which they have participated during the two years following the date of their departure from office.
Similarly, paragraph 6 of the same article establishes the obligation for high-level officials to declare to the Conflict of Interest Office the activities they intend to carry out after holding public office, prior to the commencement of such activities. Within one month of receipt of the declaration, the Conflict-of-Interest Office must issue an opinion on the compatibility of the envisaged activities with the law and notify both the former public official and the private entity concerned of its decision.
Source: (Government of Spain, 2015[14]).
Additionally, when a declaration concerning post-employment activities indicates a potential or perceived conflict of interest, the Dominican Republic could expressly empower the competent bodies or units to investigate such cases and issue formal opinions, following the model of France’s High Authority for Transparency in Public Life (HATVP) (Box 2.7).
In France, the HATVP is responsible, among other functions, for the oversight of pre- and post-public employment situations, alongside direct control lead by hierarchic authorities. Pursuant to Article 23 of Law No. 907-2013, the HATVP directly examines the post-employment activities of high-level public officials –including ministers, mayors of large cities, heads of regulatory authorities and high-level civil servants– in order to identify potential criminal risks, ethical risks and risks of conflict of interest.
For a period of three years, anyone who has held one of these positions must refer to the HATVP to examine whether the new private activities that they plan to exercise are compatible with their former functions.
The scope of activities subject to review and authorisation includes both the exercise of self-employed activities and the performance of remunerated activities in public or private companies or interest groups that maintain commercial or industrial relations with the State.
The HATVP initiates its investigation after receiving notification from the person concerned or when it detects that a person is carrying out an unauthorised activity. The authority must issue an opinion within two months, during which the person under investigation has the right to submit comments and evidence. The investigation may culminate in:
an opinion of compatibility
an opinion of compatibility with reservations, in which it imposes precautionary measures likely to prevent the criminal and ethical risk, applicable for a period of up to three years
an opinion of incompatibility prohibiting the performance of the activity for a period of up to three years, mostly in cases where the planned activity exposed the person concerned to a criminal risk.
Once the procedure has been completed, the HATVP notifies its decision both to the person concerned and, where appropriate, to the employing company. In the event of an opinion of incompatibility, the person concerned must immediately cease the activity, and contracts entered into in contravention of such a decision shall be cancelled. Failure to comply with an opinion of incompatibility may result in criminal sanctions, including imprisonment of up to one year and fines of up to EUR 15 000.
For civil servants, non-compliance with an opinion of incompatibility or the failure to refer a planned activity to the HATVP where required may also give rise to specific administrative sanctions under Article L. 124-20 of the General Civil Service Code (disciplinary measures, deductions from the pension of retired civil servants, and the termination of the new employment contract without notice or compensation).
For public servants, since the Law of 6 August 2019 on the Modernisation of the public service, this control has been internalised as it is carried out by the hierarchical superior of the public servant concerned, who can consult the ethics officer if there is a difficulty. The internalised ethical control may require the intervention of the HATVP, according to a principle of subsidiarity: if the hierarchical authority has serious doubts about the project in question.
Source: (Government of France, 2013[15]).
The Dominican Republic could also establish a specific sanctioning regime for cases of non-compliance with the restrictions applicable before and after the exercise of public office. Good practice in OECD Member countries shows that a combination of administrative, disciplinary and criminal sanctions is more effective in promoting compliance with such regulatory frameworks (OECD, 2025[16]). In this regard, the Dominican Republic could consider defining clear, specific and proportional sanctions, tiered according to the seriousness of the breach.
To safeguard proportionality, the Dominican authorities could classify offences according to their level of seriousness and attach corresponding sanctions to each category. For example, accepting an offer of employment in violation of the cooling-off period may be considered a more serious offence given its potential integrity risks, while failure to declare prior employment in the declaration of interests may constitute a less serious offence, depending on the circumstances and intent. Moreover, sanctions for more senior public officials should be stricter, given their higher level of responsibility and risk.
Sanctions could include, inter alia, administrative measures such as removal from office (in the case of violations related to employment prior to public office), temporary disqualification from holding public office, restrictions on access to future positions and administrative fines. In the case of public officials exposed to high levels of risk, criminal sanctions could also be envisaged.
Finally, the Dominican Republic could consider mechanisms to promote private sector compliance with post-public employment restrictions. In particular, specific sanctions could be established for legal entities hiring former public officials subject to such restrictions, recognising that companies also share the responsibility to act with integrity and to prevent conduct that undermines public trust. These sanctions could include fines, payment of damages, as well as more specific measures, such as temporary disqualification from contracting with the State. Box 2.8 presents an example of measures taken in Spain to hold the private sector accountable for non-compliance with post-public employment restrictions.
In Spain, restrictions on the post-public employment of senior officials are regulated by Law No. 3-2015. Article 26 of this law establishes sanctions for public officials who commit serious or very serious offences, including prohibition from holding public office for a period of between five and ten years. Similarly, former public officials may be required to repay compensation and indemnities received during the cooling-off period.
The Spanish legal framework also imposes obligations on the private sector. In particular, Law No. 9-2017 on Public Sector Contracts (Article 71) provides that companies entering into contracts with the State that have recruited persons subject to the two-year cooling-off period, in contravention of the prohibition on providing services in private companies directly related to the responsibilities of their former position, shall be disqualified from contracting with any public body, provided that the breach has been published in the Official State Gazette. Such disqualification is maintained for as long as the person remains employed, with a maximum limit of two years from the date of termination of their employment as a senior official.
Source: (Government of Spain, 2015[14]).
2.2.6. The Dominican Republic could establish further provisions to ensure implementation and enforcement of gift and gratuities management
A conflict of interest, or the perception of a conflict of interest, can also arise when public officials receive gifts and/or gratuities from third parties. Gifts and gratuities given to public officials may, directly or indirectly and even unconsciously, influence the performance of their duties and decisions or be reasonably perceived as such. Gifts and gratuities include invitations for decision-makers to participate in events, seminars and conferences, or sponsorship of initiatives without due transparency (OECD, 2004[4]).
The Dominican Republic prohibits the acceptance of gifts and gratuities through Article 80 in Law No. 41-2008, which establishes that it is prohibited to “solicit, accept or receive, directly or through an intermediary, gratuities, gifts, presents, commissions or rewards...”. However, the legal framework lacks complementary provisions, including mechanisms for monitoring and verifying compliance.
First, although Law No. 41-2008 already provides for the obligation to categorically refuse any gift or gratuity, this provision does not currently extend to family members of public officials. Considering that gifts and gratuities given to family members may also lead to situations of conflict of interest, an express prohibition for family members of public officials –such as spouses and children– could be included.
Second, while the general prohibition on accepting gifts and gratuities should remain the rule, the legal framework could provide clear procedures for those exceptional circumstances unsolicited gifts or gratuities related to the performance of official duties cannot reasonably be refused, for example, gifts received during official visits of foreign dignitaries. In such cases, public officials could be required to declare the gift in a publicly accessible register, which, within the executive branch, could be managed by the DIGEIG. Public officials could also be required to surrender such gifts to a competent authority responsible for determining their final disposition.
Finally, responsibility for overseeing compliance with the rules governing gifts and gratuities should be clearly assigned to a competent authority. In addition, the legal framework could establish an effective, dissuasive and proportionate system of consequences, including specific sanctions for the improper acceptance of gifts and gratuities, the failure to register gifts received under exceptional circumstances in the public access system, and non-compliance with the obligation to hand them over to the competent authority.
Asset declarations constitute an important component of a broader conflict-of-interest management system, complementing the preventive role of interest disclosures. While interest disclosures, as discussed above, are designed to identify and manage conflict of interest before it arises, asset declarations, which cover pecuniary interests (income, assets, liabilities, expenses, etc.) provide a mechanism for monitoring the financial situation of public officials overtime, thereby contributing to strengthened transparency (OECD, 2011[17]). In this sense, asset declarations are a key tool for detecting and investigating the illicit enrichment or unjustified wealth of public officials, investigating corruption offences, and ultimately recovering assets.
In the Dominican Republic, Law No. 311-2014 and Decree No. 92-2016 establish the legal framework for asset declarations, which includes the National Automated and Uniform System of Sworn Asset Declarations (Sistema Nacional Automatizado y Uniforme de Declaraciones Juradas de Patrimonio), and set out the institutions responsible for its implementation. The legal framework further defines the universe of public officials required to file an asset declaration, how and when the declaration must be made, the content of the declaration, the bodies responsible for its verification, inspection and analysis, and the sanctions for non-compliance. The Chamber of Accounts of the Dominican Republic (Cámara de Cuentas de la República Dominicana) is designated as the body responsible for controlling compliance with the obligation to submit an asset declaration and for auditing its content.
The following is an analysis of the Dominican Republic's asset declaration system, the National Automated and Uniform System of Sworn Asset Declarations and its implementation in practice, and provides concrete recommendations for strengthening.
2.3.1. The Dominican Republic could include advisors in the list of individuals subject to the obligation to declare their assets
There is no standard list of public officials that an asset declaration system should cover (World Bank/UNODC, 2023[18]). Instead, the declarant population should reflect an analysis of the risk of corruption in the different positions and areas of the public sector, and take into account considerations on the effectiveness and impact of the system (World Bank/UNODC, 2023[18]).
The scope of the Dominican Republic's asset declaration system applies to all three branches of the State, including banks and state-owned enterprises, the military and the police. Furthermore, it takes a risk-based approach requiring only those who face a higher risk of corruption due to their position to submit a declaration. Article 3 of Decree No. 92-2016 elaborates the universe of public officials required to file an asset declaration and includes high-level public officials, administrative and financial directors, and those in charge of purchasing and procurement in various constitutional bodies and entities, in the central government and its decentralised agencies, in state-owned enterprises, and in Local Administration bodies, namely:
Presidency of the Republic, ministries, centralised or deconcentrated bodies, decentralised agencies and autonomous bodies, National Congress, Judiciary, Constitutional Court, Superior Electoral Court, Office of the Attorney General of the Republic, Ombudsman's Office, Central Electoral Board, Foreign Service and Chancellery, Chamber of Accounts, Office of the Comptroller General of the Republic, National Treasury, Central Bank, Monetary Board, National Social Security Council, Armed Forces and National Police, state-owned banks and companies, state-owned universities and public hospitals.
This focused and reduced approach based on the level of risk at the Dominican Republic is in line with international good practice and, according to the OECD Public Integrity Indicators, with 74% of OECD Member countries. The list of public officials established by Law No. 311-2014 and Decree No. 92-2016 covers high-risk positions both in terms of their hierarchical level and the nature of the activities they carry out.
However, key positions are missing, in particular those holding advisory positions. To that end, the Dominican Republic could consider expanding this list to also include persons holding advisory positions in the executive branch. This is particularly relevant given that advisers, as high-level officials in positions of trust in the highest authorities of public institutions, can exert significant influence on public decision-making and are exposed to a higher risk of capture or corruption. Moreover, as they typically hold positions of free appointment and removal, their appointment and removal depend entirely on the discretion of these authorities, which may increase their vulnerability to any potential improper influence.
2.3.2. The Dominican Republic could strengthen efforts to ensure that the Chamber of Accounts receives updated information on individuals subject to filling an asset declaration
While the scope of declarants is risk-based and comprehensive, significant implementation challenges remain. In practice, the Chamber of Accounts does not have complete and up-to-date information on the public officials who are required to file an asset declaration at any given time. In particular, the Chamber of Accounts is not systematically informed of new appointments, promotions, transfers, or departures from public office. As a result, it is impossible for the Chamber of Accounts to monitor compliance with the law and verify potential cases of unjustified wealth and illicit enrichment comprehensively.
Additionally, there is no centralised human resources information system covering the entire public administration (see also Chapter 3). Personnel information is dispersed across individual public institutions, making it difficult to maintain an accurate and continuously updated register of officials subject to the asset declaration regime. Although Article 7 of Law No. 311-2014 requires both public officials and the authorities responsible for their appointment or election to notify the Chamber of Accounts of every appointment, election and termination of office, stakeholders interviews for this Integrity Review indicated that this obligation is not consistently fulfilled in practice.
To address the problem, the Chamber of Accounts created a digital platform, in which access to information offices and human resources units from each public institution are required to provide information on incoming, promoted and departing public officials. While the digital platform is a welcome addition, challenges remain in ensuring information is submitted.
To support implementation, Decree No. 343-2022 established the Commission for Compliance of Public Officials with Sworn Asset Declarations (Comisión para el Cumplimiento de Declaraciones Juradas de Patrimonio de los Funcionarios y Servidores Públicos) in the executive branch. The Commission brings together the DIGEIG, the Ministry of Public Administration (Ministerio de Administración Pública, MAP), the Ministry of Foreign Affairs (Ministerio de Relaciones Exteriores), the Office of the Comptroller General of the Republic, and the Legal Consultancy to the Executive Branch (Consultoría Jurídica del Poder Ejecutivo). Stakeholders consulted during the fact-finding mission welcomed this initiative but noted that its effectiveness will depend on sustained inter-institutional co-operation and consistent compliance by all public institutions. In particular, ensuring that human resources units and access to information offices regularly update the platform will be critical for maintaining an accurate and complete register of declarants.
The Chamber of Accounts should therefore continue its efforts to operationalise the digital platform and ensure that it contains accurate, updated and, where feasible, real-time information on all public officials required to declare their assets. To support this objective, public institutions at the national and sub-national levels, as well as across all branches of the State, should renew their commitment and strengthen compliance with the legal obligation to report appointments, changes in functions and departures from public office. To facilitate this, each institution could designate one or more focal points –preferably within the human resources and access to information offices– to be responsible for regularly updating the institution's register of declarants.
In addition, to facilitate implementation, the Chamber of Accounts could develop a targeted training programme for these institutional focal points, focusing on the criteria for determining which public officials are subject to asset declaration requirements and on the procedures for updating the digital platform. The training materials, frequently asked questions and practical guidance could be consolidated into an online resource available on the Chamber of Accounts’ website for quick reference in case of concerns.
2.3.3. The Dominican Republic could introduce a periodic asset declaration during the term of office
To ensure that asset declarations serve their intended purpose –that is, wealth monitoring and detection of illicit enrichment– regular reporting intervals are essential. For example, the reporting cycle of a candidate for public office could include (1) declaration of assets upon announcing candidature, (2) a declaration upon entering public office, (3) periodically throughout tenure (4) before or upon leaving office, and (5) one or two years after leaving office (if post-public employment rules apply) (Pop, Kotlyar and Rossi, 2023[19]). In addition, there may also be declarations to correct information declared during a grace period after the deadline for submission, or ad hoc declarations when requested (e.g. if there are indications of unjustified wealth) or to report significant changes in assets between periodic declarations (Pop, Kotlyar and Rossi, 2023[19]).
In the Dominican Republic, the reporting cycle is laid out in Law No. 311-2014 (Articles 5 and 6), which establishes the obligation to submit an initial asset declaration within 30 days of taking office, the commencement of a new position or re-election for a new term, and a final asset declaration within 30 days of leaving office. In addition, the Chamber of Accounts is empowered to request ad hoc asset declarations when it deems necessary in the framework of an investigation. Decree No. 92-2016 (Article 14) complements the existing type of declarations with a second type of ad hoc declaration: voluntary update for any change in assets during the term of office or for any other reason that the public official deems relevant.
However, the law currently does not require periodic declarations (such as annual or biannual) throughout one’s tenure, which is a key reporting obligation to help increase early detection of corruption and illicit enrichment schemes (Dominguez, 2024[20]). To that end, the Dominican Republic could consider requiring by law that asset declarations are also updated periodically, either annually or biannually (taking into consideration resources, personnel and budget of the Chamber of Accounts). In applying this change, the Dominican Republic could clearly define and communicate the reporting period, that is, the time frame to which the declared information relates, such as income received during the previous two calendar years, with each year running from January to December (Pop, Kotlyar and Rossi, 2023[19]). Once these elements are established, key dates, including reporting periods and deadlines, should be clearly communicated to support public officials' in meeting their obligations. In addition, the capacity of the Chamber of Accounts should be assessed to determine whether additional staff are needed for verification, inspection and audit.
2.3.4. The Chamber of Accounts could develop a handbook and guidelines to help individuals subject to the obligation to declare in completing their asset declarations
The categories of assets, amount of information and level of detail required in declarations vary across countries, depending on the objectives of the disclosure system and applicable legal and administrative framework (OECD, 2023[21]). Nevertheless, most systems require similar core information, typically covering movable and immovable assets, liabilities, financial and business interests, external positions, and income and sources of income (OECD, 2023[21]).
In the Dominican Republic, Law No. 311-2014 sets out the minimum content of asset declarations, while Decree No. 92-2016 requires additional information and provides further details on the declaration’s content. The resulting declaration requirements are comprehensive and aligned with international good practice, and include movable and immovable property, income and sources of income, membership of collegial bodies, credits and debts, capital and shares, information on family members (spouse, children and parents), and assets held within the declarant’s marital estate, among others.
However, asset declarations do not only depend on the legal obligation to declare assets and the regulatory framework, but also on the quality of the information provided by public officials (OECD, 2023[21]). Therefore, ensuring that the forms are understood and completed correctly, and that there is access to guidance where necessary, is a key part of the success of any asset declaration system. Indeed, the very act of completing a declaration can strengthen the integrity of public officials, as they must first conduct a self-assessment to identify what assets they possess and to what extent these might undermine their ability to serve the public interest.
In this regard, the Chamber of Accounts could consider developing guidelines on how to complete asset declarations. The guidelines could include examples of the types of assets under each category to promote reflection, as well as “lessons learned” sections from previous cases of incorrect or erroneous declarations. To further facilitate implementation, the Chamber of Accounts could also establish a “help desk” to provide guidance and support to individuals required to file asset declarations. This service could be particularly valuable during periods of high filing activity, such as at the beginning of a presidential term or when periodic asset declarations are due. The Dominican Republic could draw inspiration from international good practices for the development of these rules and guidance (see Box 2.9).
Countries can provide support mechanisms for those filing asset declarations, for example, through the development of websites, designated staff, telephone helplines, detailed guides and FAQ sections attached to the blank forms.
In Brazil, the Office of the Comptroller General (Controladoria-Geral da União, CGU) manages the asset declaration system for federal public officials. Declarations are filed online by means of the Electronic System of Asset and Conflict-of-Interest Information Sistema (Eletrônico de Informações Patrimoniais e de Conflito de Interesses - e-Patri). The website of the Office of the Comptroller General provides information on who must disclose, what must be disclosed, when and how to disclose, as well as the legal framework for the disclosure process. In addition, there is an FAQ section and a handbook containing detailed guidance on how to fill in the form.
Source: (OECD, 2025[22]; CGU, n.d.[23]).
2.3.5. The Chamber of Accounts could strengthen processes for the submission, verification, inspection and control of asset declarations
Accurate completion of asset declarations is a necessary but insufficient condition for their effectiveness. Without clear and well-functioning processes for receiving, registering, and storing declarations, there is a risk that information is incomplete, inaccessible, or inconsistently managed. Equally, robust verification mechanisms are essential to assess the accuracy and plausibility of the information provided. Without systematic checks and follow up, declarations remain a formal exercise rather than a meaningful tool for detecting irregularities, undermining their role in strengthening transparency and accountability.
According to Decree No. 92-2016, the asset declaration must be submitted electronically through the National Automated and Uniform System of Asset Declarations of the Chamber of Accounts, as well as in physical form, signed before a public notary, together with a paper copy of the supporting documents. Once the digital declaration has been received, the Chamber of Accounts begins the process of verification, inspection and audit of the asset declarations, which consists of the following steps:
Verification: the Chamber of Accounts checks the digital form to determine whether the declaration was submitted on time and whether it contains all the required information. Should information be missing, the auditor may contact the public official to request that they complete their digital declaration.
Inspection: Once the physical file has been received, the Chamber of Accounts defines the order in which the inspection of the asset declarations will be carried out. For this purpose, a prioritisation methodology is used that considers six criteria, including the declarant's total assets and change in net worth, as well as the total budget and procurement volume of the declarant's agency. The inspection seeks to determine inconsistencies in the information reported.
Audit: In the case of declarations where the inspection has flagged inconsistencies, the Chamber of Accounts proceeds with the audit. At this stage, the Chamber of Accounts may request information from third parties such as the Superintendency of Banks and the Directorate General of Internal Taxes (Dirección General de Impuestos Internos). Law No. 311-2014 establishes a maximum period of ten (10) days for the institutions to provide the requested information, or the corresponding sanctions will be imposed. If anomalies that could be criminal offences are found, the Chamber of Accounts must forward the reports to the Office of the Attorney General of the Republic for investigation.
Since 2018, the Chamber of Accounts has issued almost 1900 verification reports and 24 audit reports (Table 2.5); these reports were approved by a plenary decision of the Chamber of Accounts.
Note: The verification reports for the year 2023 refer to reports prepared that are awaiting review by the plenary of the Chamber of Accounts. The verification reports for the year 2024 refer to reports prepared by the area in the review phase before being submitted to the plenary of the Chamber of Accounts. The audit reports for the year 2024 refer to reports prepared by the area awaiting information from third parties prior to completion. The total number of reports approved does not include reports awaiting review by the plenary and/or the submission of information from third parties.
Source: Information provided by the Chamber of Accounts of the Dominican Republic in April 2025.
While comprehensive, the procedure described above presents several areas for additional improvement. In particular, with regard to the process of submission of declarations, it is recommended that the Chamber of Accounts continue to develop and implement the National Automated and Uniform System of Asset Declarations, so that 100% of declarations are submitted electronically, thus eliminating the need to physically submit declarations or supporting documents. Indeed, managing a paper-based system involves significant challenges and costs, which can be eliminated by using an electronic system (World Bank/UNODC, 2023[18]). The benefits of an electronic system include simplifying the filing process by making the form easier to use, reducing errors in declarations, speeding up verification, and improving data management and security (World Bank/UNODC, 2023[18]). Once the electronic system is sufficiently robust, the Dominican Republic could consider amending Law No. 311-2014 and Decree No. 92-2016 to abolish the requirements for the physical filing of these documents.
With regards to the process for inspecting the declarations, the Chamber of Accounts has designed a risk-based methodology to prioritise the audit stage. This aligns with international good practice, which underscores the value of focusing verification efforts on higher risk cases, particularly where the volume of declarations to be verified is high (World Bank/UNODC, 2023[18]). To strengthen the risk-based approach, the Chamber of Accounts could establish a clear regulatory procedure defining the scope of the inspection stage and the inconsistencies in the reported information that should automatically trigger an audit. This involves defining exactly which situations create an alert and which do not, in order to ensure transparent and objective criteria that limit discretion in decision-making.
As for the auditing process for declarations, for an asset declaration system to be effective, the entity responsible for verifying asset declarations must have adequate human and financial resources to perform this role (OECD, 2023[21]). In this context and considering that the Chamber of Accounts started auditing declarations only in 2021 (see Table 2.5), it is recommended to strengthen the team in charge of this process. To this end, it is suggested that a larger multidisciplinary team be set up, equipped with the necessary technological tools and training to conduct a rigorous audit of the declarations. This could include the creation of specific professional profiles in line with the needs of the Chamber of Accounts, as well as the implementation of merit-based selection processes in order to ensure quality and professionalism in auditing.
In addition, there are major challenges for effective co-ordination between the different institutions that have information relevant to the audit process. Stakeholders interviewed during the fact-finding mission for this Integrity Review indicated that, although Law No. 311-2014 establishes deadlines for the submission of information to the Chamber of Accounts in the framework of the audit process, institutions rarely submit the requested information within the required timeframe or with the required quality. In this regard, to strengthen the quality and timeliness of the information to be used in the verification process, the Dominican Republic may consider implementing several actions:
Establish protocols with relevant entities, such as the Office of the Attorney General of the Republic (Ministerio Público), the Superintendency of Banks (Superintendencia de Bancos) and the Directorate General of Internal Taxes to ensure better co-ordination and facilitate the exchange of relevant information. Examples from other countries could be useful for the Chamber of Accounts of the Dominican Republic (Box 2.10).
Establish and implement a clear and proportionate system of consequences for failure to submit the information required by the Chamber of Accounts in a timely manner in the framework of the audit process.
To fulfil its mandate, the French High Authority for Transparency in Public Life (HATVP) requires a high level of co-ordination and co-operation with institutions and individuals that possess useful information for the process of monitoring asset and interest declarations. In this regard, the HATVP has signed several inter-institutional agreements and protocols with public entities, aimed at ensuring better co-ordination and facilitating the exchange of relevant information:
In 2016, the HATVP and the tax administration signed a protocol to clarify their relationship. Since January 2017, HATVP personnel have been allowed to connect directly to some tax administration databases and applications to perform routine checks, especially to value real estate, access the list of registered bank accounts or check property registry information.
In September 2017, the HATVP and the National Anti-Money Laundering Service signed a protocol. This protocol, together with the legislative developments in December 2016, allows both institutions to share information relevant to their respective controls and investigation procedures.
Regarding co-operation with the courts, HATVP and the Directorate of Criminal Affairs and Pardons, as well as HATVP and the General Prosecutor's Office, signed a memorandum and an instruction, respectively, to formalise procedures for exchanging information with public prosecutors and audit tribunals.
In 2019, the HATVP signed a protocol with the French Anti-Corruption Agency to ensure better co-ordination of actions between the two institutions, the missions of which are complementary.
Source: (HATVP, n.d.[24]).
Regarding sanctions, Law No. 311-2014 and Decree No. 92-2016 establish sanctions for non-compliance with the obligations related to the system of asset declarations. Sanctions are established for:
Failure to declare: this is considered a serious or third-degree offence, as the case may be, and the sanctions are provided for in Law No. 41-2008. Moreover, salary withholding is included as a legal consequence of failure to submit the asset declaration within the deadline until remedied.
Falsification of data: which carries a prison term of one (1) to two (2) years and a fine of twenty (20) to forty (40) times the minimum salary of the Central Government.
Illicit enrichment: which carries a prison term of four (4) to ten (10) years, a fine equivalent to twice the amount of the increase, and disqualification from holding public office for a period of ten (10) years.
However, stakeholders interviewed during the fact-finding mission for this Integrity Review reported that, as of 2025, no sanctions have ever been imposed for non-compliance with the obligations relating to the system of asset declarations; this is reinforced by the OECD Public Integrity Indicators, which find that no data is systematically collected on sanctions. This could be linked to two factors. On the one hand, it is only since 2021 that the Chamber of Accounts has been carrying out inspections and audits of declarations. On the other hand, sanctions, such as salary withholding, are not directly enforced by the Chamber of Accounts, which implies that their enforcement requires inter-institutional co-ordination and a commitment from different public entities. In turn, the lack of sanctions regarding failure to submit declarations has a negative impact on the reputation and credibility of the asset declarations system.
Considering the above, the Chamber of Accounts should strengthen its capabilities to complete the verification, inspection and audit phases of the asset declarations of Dominican public officials and inform the competent authorities when it detects any non-compliance or irregularity in the declarations. In the framework of these processes, statistics should also be compiled on the number of declarations reviewed, number of non-compliances due to failure to submit, falsification and enrichment, number of cases transferred to the Office of the Attorney General of the Republic, among others, to strengthen the understanding of the functioning of the system and to make evidence-based decisions. For their part, the authorities responsible for imposing sanctions, including the National Treasury (Tesorería Nacional) in the case of salary withholding, should renew their commitment to the system of asset declarations and ensure that they fulfil their obligations. In addition, the Chamber of Accounts could consider including general information on the functioning of the system of asset declarations in its accountability exercises to the public, making use of the statistics collected.
2.3.6. The Chamber of Accounts could publish in open data format the non-confidential section of the asset declarations of public officials
There are benefits to proactively disclosing certain information in the asset declaration system. On the one hand, it allows external stakeholders, including the media, civil society organisations and individuals, to review declarations and report inconsistencies to the authorities. On the other, it fosters accountability as public officials must be prepared to provide explanations regarding the data disclosed (OECD, 2011[17]).
In the Dominican Republic, Law No. 311-2014 (Article 22) establishes the obligation to publish on the website of the Chamber of Accounts the non-confidential section of each public official’s asset declaration. In addition, Decree No. 92-2016 (Article 17) clarifies which data are of a confidential and personal nature in the asset declaration and therefore cannot be published, namely: the declarant’s personal information, personal information relating to family members, information relating to the identification number of the bank account, identification number of registered property or sufficient data to locate the property. This is in line with international good practices that promote a balance between transparency and protection of individual privacy (World Bank/UNODC, 2023[18]).
In practice, the non-confidential section of the asset declaration is effectively published on the website of the Chamber of Accounts. However, the publication format makes it difficult for external stakeholders to use this information. In this regard, the Chamber of Accounts could publish in open data format the non-confidential section of the asset declarations of public officials subject to the obligation to file asset declarations, in order to facilitate their re-use by external stakeholders and contribute to the emergence of new data analysis tools and monitoring initiatives.
Developing a comprehensive framework for identifying and managing conflict of interest
The Dominical Republic could clearly define key concepts such as real, potential and perceived conflict of interest, and private interest.
The Dominican Republic could establish specific obligations for public officials to declare their private interests and manage their conflict of interest, as well as clear procedures for such purposes.
The Dominican Republic could define clear institutional responsibilities for the conflict-of-interest management system, including roles for providing advice and guidance, and monitoring and verification.
The Dominican Republic could ensure that sanctions for breaches of the conflict-of-interest obligations are defined and clear responsibilities for investigation and enforcement are established.
The Dominican Republic could establish measures to mitigate integrity risks and manage conflict of interest on pre- and post-public employment in the legislation.
The Dominican Republic could establish further provisions to ensure implementation and enforcement of gift and gratuities management.
Strengthening the asset declarations system for effective detection
The Dominican Republic could include advisors in the list of individuals subject to the obligation to declare their assets.
The Dominican Republic could strengthen efforts to ensure that the Chamber of Accounts receives updated information on individuals subject to filing an asset declaration
The Dominican Republic could introduce a periodic asset declaration during the term of office.
The Chamber of Accounts could develop a handbook and guidelines to help individuals subject to the obligation to declare in completing their asset declarations.
The Chamber of Accounts could strengthen processes for the submission, verification, inspection and control of asset declarations.
The Chamber of Accounts could publish in open data format the non-confidential section of the asset declarations of public officials.
References
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