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Natural Resources and Violent Conflict - WaterWiki.net

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190 winer <strong>and</strong> roule• Require that financial accounts be drawn up of companies organizedin the jurisdiction in accordance with generally accepted accountingst<strong>and</strong>ards <strong>and</strong> that they be appropriately audited• Put into place mechanisms for the jurisdiction to share informationpertaining to tax offenses with corresponding authorities in otherjurisdictions• Ensure that its regulatory <strong>and</strong> tax authorities have access tobank information that may be relevant for the investigation or prosecutionof criminal tax matters.In particular, agreement to share information on the ownership ofcompanies, regardless of where they are located, to require appropriateaudits of each company organized in a jurisdiction, to require suchaudits to become available to the public, at least for publicly tradedfirms, <strong>and</strong> to match tax information with bank information <strong>and</strong> therecords maintained by the business of its activities all have potentialapplicability to efforts to punish those exploiting revenue streams fromillicit commodity extraction.Gaps <strong>and</strong> Possible Institutional ResponsesToday a patchwork of initiatives for monitoring illicit commoditiesinvolves numerous institutions, none of which has broad jurisdiction overthe tracking of natural resource commodities <strong>and</strong> the proceeds of theirexploration. Moreover, none of the initiatives has sought to develop areporting or disclosure mechanism to create documentation that wouldsimultaneously track the physical transactions <strong>and</strong> movement of commodities<strong>and</strong> funds. The Publish What You Pay initiative wouldprovide a precursor to such tracking by providing documentation atthe front end of commodity transactions, such as oil <strong>and</strong> gas, that involvehighly concentrated markets of both sellers <strong>and</strong> buyers. Similarly,the Wolfsberg initiative, which includes an obligation to exerciseheightened scrutiny of large private bank accounts, could also providea structure applicable to tracking the funds generated by the sale ofnatural resources. The existing Wolfsberg principles already requireparticipating institutions to impose higher levels of scrutiny on certaintypes of transactions in some regions to determine whether they mightbe the proceeds of corruption. Thus they could help to create greateraccountability over the illicit proceeds of commodity exploitation,should typologies for such exploitation <strong>and</strong> “red flags” be developed toindicate that illicit proceeds from commodity extraction are beinglaundered.

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