Related to the Output 2.2 of the project, the overall objective of the assignment is to strengthen the LACC's legal, investigative and verification tools for enforcing the asset declaration regime and combating corruption, including in the natural resources sector, in line with the LACC National Strategy (2026–2030).

Specific objectives include:

1.   Develop a legal Sanctions Framework for non-compliance with asset declaration requirements, with particular attention to officials exiting government service.

2.   Strengthen the LACC's investigation and prosecution capacity through case-selection guidelines, standard operating procedures, hands-on coaching, and specialized training in procurement fraud and tax crime investigation and in ethics and anti-corruption administration.

3.   Strengthen the capacity of the LACC's Verification Unit to cross-reference asset declarations with bank and property records to detect discrepancies indicative of unexplained wealth.

4.   Support the capacity of the LACC's natural resources team to identify, assess and pursue corruption risks in the natural resources and concessions sector.

Under the overall guidance of the LACC, the consultant/firm will deliver the assignment through four parts, described below. Given the sensitivity of the subject matter, all work will be carried out in close coordination with LACC leadership and Expertise France and subject to the confidentiality and integrity safeguards set out in Section 12.

Part 1: Legal Sanctions Framework for Asset Declaration Non-Compliance

Objective: Support the LACC in drafting a legal Sanctions Framework for non-compliance with asset declaration requirements, specifically for officials exiting government. Tasks include:

•     Review the current legal and regulatory framework governing asset declarations (including the Code of Conduct Act, the LACC Act and related regulations) and assess the adequacy of existing sanctions and enforcement provisions, with particular attention to gaps affecting officials at the point of exit from government service.

•     Conduct a comparative review of sanctions regimes for asset-declaration non-compliance in comparable jurisdictions, to inform options for Liberia (e.g., graduated administrative fines, referral for prosecution, disqualification from future public office, publication of non-compliance).

•     Draft a Sanctions Framework (policy paper and accompanying draft legal instrument – regulation, directive or legislative amendment as appropriate) that defines categories of non-compliance (non-filing, late filing, false or incomplete declaration, failure to file an exit declaration), the corresponding graduated sanctions, the procedure for triggering and applying sanctions, and due-process/appeal rights.

•     Clarify institutional roles and responsibilities for enforcement across the LACC, the Ministry of Justice, the Civil Service Agency and employing institutions, including the specific procedure for exit clearance tied to asset declaration compliance.

•     Facilitate validation consultations with LACC leadership and relevant stakeholders (e.g., Ministry of Justice, Civil Service Agency, Legislature as required) on the draft Sanctions Framework, and support the LACC in revising and finalizing it for submission through the applicable approval process.

•     Develop an implementation/roll-out plan and plain-language communication materials to inform public officials – particularly those exiting government – of their obligations and the consequences of non-compliance.

Part 2: Investigation and Prosecution Capacity

Objective: Strengthen the LACC's capacity to investigate and prosecute corruption cases. Tasks include:

•     Develop guidelines for selecting cases for investigation, including risk-based prioritization criteria, an intake/triage process, and criteria for referral to other agencies where appropriate.

•     Develop standard operating procedures (SOPs) for the conduct of investigations and prosecutions, covering case planning, evidence gathering and preservation (including chain of custody), case file management, and the handover/referral process to prosecutorial authorities.

•     Support the LACC through hands-on coaching – working alongside LACC investigators and prosecutors on live or recent case files – to investigate and prosecute corruption cases using the new guidelines and SOPs.

•     Build the capacity of investigators in procurement fraud investigation (e.g., bid-rigging, collusion, kickbacks, contract manipulation) and tax crime investigation (e.g., tax evasion typologies and financial investigation techniques), using case studies and, where available, real or de-identified case material.

•     Deliver training in ethics and anti-corruption administration, covering professional ethics and integrity for investigators and prosecutors, and core principles of anti-corruption administration.

Part 3: Verification Capacity

Objective: Support the LACC's Verification Unit in cross-referencing asset declarations with bank and property records. Tasks include:

•     Assess the Verification Unit's current processes, staffing, tools and access to external data sources, and identify practical constraints to effective verification.

•     Develop or strengthen a verification methodology and SOPs for cross-referencing declared assets against bank records and property records, including data-matching techniques and red-flag indicators of discrepancy between declared and actual holdings.

•     Support the LACC in establishing or strengthening data-sharing arrangements (e.g., through the Central Bank of Liberia for bank records, and the relevant land/property registry) needed to enable systematic verification, including template information-sharing protocols or memoranda of understanding.

•     Train Verification Unit staff in the verification methodology, any associated tools, and the process for escalating confirmed discrepancies to the investigation function under Component 2.

•     Support a pilot verification exercise on a sample of declarations – prioritizing exit declarations – to test and refine the methodology under real conditions.

Part 4: Support to the Natural Resources Team

Objective: Strengthen the capacity of the LACC's natural resources team to identify and address corruption risks in the management of Liberia's natural resources. Tasks include (final scope to be confirmed with the LACC at inception, given Liberia's extractive-dependent economy and overlapping mandates with sector regulators):

•     Assess the current mandate, workflow and capacity of the LACC's natural resources team, and its working relationships with relevant sector institutions (e.g., Ministry of Mines and Energy, Forestry Development Authority, Liberia Extractive Industries Transparency Initiative).

•     Develop practical tools and checklists for reviewing mining, forestry and other natural resource concession agreements and licensing processes for corruption risk indicators, building on the concession-review techniques used elsewhere in the audit and oversight system.

•     Provide coaching support to the natural resources team on applying these tools to actual concessions or licensing files, and on investigating suspected corruption in natural resource management (e.g., irregular license allocation, revenue leakage, illegal logging or mining).

•     Support structured information-sharing arrangements between the natural resources team and relevant sector institutions and, where relevant, the Verification Unit and investigation function under Components 2–3.

•     Deliver targeted training for the natural resources team on natural resource governance and anti-corruption principles specific to the extractives sector.

The consultant is expected to propose a detailed methodology in its technical proposal, but the approach should, at minimum:

•     Be diagnostic-led, beginning with a review of the existing legal framework, procedures and institutional capacity in each component area before drafting instruments or designing training.

•     Combine legal/policy drafting with practical, coaching-based capacity building – working alongside LACC staff on real or recent cases and files rather than classroom-only delivery.

•     Treat the four components as mutually reinforcing: The Sanctions Framework (Component 1) depends on investigation capacity (Component 2) and verification evidence (Component 3) to be enforceable, and natural resources corruption risks (Component 4) draw on the same investigative and verification skill sets.

•     Build in validation steps with LACC leadership and relevant external stakeholders (Ministry of Justice, Civil Service Agency, Central Bank of Liberia, sector regulators) at key milestones, particularly before finalizing the Sanctions Framework.

•     Plan explicitly for institutional sustainability: guidelines, SOPs, templates and a facilitator/handover pack that LACC units can own and apply after the assignment ends.

The following deliverables are indicative and should be refined and agreed with Expertise France at inception. All deliverables are subject to review and written approval by the Expertise France before associated payments are released.

The assignment is expected to be delivered over a period of 36 months, on an intermittent basis for 32 days. The final schedule will be agreed with the LACC and Expertise France at inception, taking into account ongoing caseloads and the LACC's engagement calendar with the Legislature and other stakeholders.

The consultant/s will work under the overall supervision of Expertise France and LACC, or a designated senior official, who will serve as the primary point of contact and be responsible for reviewing and approving deliverables. The LACC will designate technical focal points for each component (e.g., heads of the Legal, Investigations, Verification and Natural Resources units) to coordinate day-to-day engagement, including access to relevant files, data and stakeholders.

The consultant/s will submit brief progress updates at agreed intervals in addition to the formal deliverables in Section 5, and will present key outputs – particularly the draft Sanctions Framework – to LACC leadership for validation before finalization.