DR Schoeman explains that corruption prevention involves measures to manage public sector integrity, avoid conflicts of interest, and includes mechanisms like financial disclosure systems, lifestyle audits, and conflict of interest management.
“So the notes start by talking about corruption prevention as a concept ... So when we talk about corruption prevention, it is all of the measures that I have just mentioned around how do we manage public sector integrity, how do we avoid conflicts of interest.”
DR Schoeman highlights three reforms in the report: financial disclosure form requirements, the institutional and operational framework for managing disclosures and corruption prevention, and the sanctions in place for consequence management.
“So effectively ... the three areas of reform that I will talk about is one, about the financial disclosure form itself ... second point being around the institutional and operational framework for how we manage financial disclosures as well as corruption prevention more broadly. And then the third point being around the sanctions in place.”
DR Schoeman explains the distinction between deterrent prevention (transparency, mechanisms to make corruption harder) and constructive prevention (ethics, ethics training, organizational culture) as key parts of the corruption prevention toolkit.
“We can essentially understand this as two types of prevention, the one being deterrent prevention ... it is about raising transparency ... The second aspect of prevention ... is around your intrinsic motivations ... constructive prevention and essentially this is the focus on ethics, on ethics training, on how you as an individual think about how you conduct yourself, your views on corruption.”
Within the government framework, there is no active push to make family members' disclosure public due to concerns about privacy rights.
“I have not yet come across a case where there is anybody within the government framework that is actively pushing for making these disclosures public. I am sure that people would have the same kinds of concerns around the right to privacy...”
No full lifestyle audits were escalated for senior management service members within the South African Police Service (SAPS) in past 5 years, only lifestyle reviews and investigations were conducted.
“Based on the lifestyle investigations conducted for senior management service members, no cases escalated to full lifestyle audits during the period under review.”
DR SCHOEMANDay 136 · 09 Jul 2026Refers to: past 5 yearsLocation: South African Police Service
Annual lifestyle reviews are conducted within SAPS with only a few escalating to lifestyle investigations, and all such investigated cases have been cleared with no referrals for lifestyle investigations between financial years 2021/22 and 2023/24 except 5 SMS members investigated and cleared in 2024/25.
“within SAPS, every year, these lifestyle reviews conducted, and some of them have led, in very few cases, to lifestyle investigations. In each case, they have been cleared... Between financial year 2021/22 and 23/24, no SAPS officials were referred for lifestyle investigation. In 24/25, 5 of 23 SMS members underwent lifestyle investigations and all were cleared.”
DR SCHOEMANDay 136 · 09 Jul 2026Refers to: 2021/22 to 2024/25Location: South African Police Service
The current SAPS lifestyle audit framework relies on financial disclosure forms reviewed by ethics officers, lifestyle investigations by departmental investigators, and forensic lifestyle audits by certified auditors, with audits outsourced to external companies due to lack of internal audit capacity.
“a lifestyle review is something that is conducted by an ethics officer within a line department... The lifestyle investigation would be conducted by an investigator... An audit is once you involve a certified auditor... In the current framework... departments are outsourcing these audits to external company...”
SAPS lifestyle investigations examine additional sources such as bank records and qualifications to detect unexplained wealth or corrupt income sources, while lifestyle audits apply forensic techniques and require more specialty skills than internal auditors usually have.
“The lifestyle investigation... would look at additional sources of info to determine unexplained wealth... lifestyle audit would be the next stage... apply forensic audit techniques... requires a very particular skill set as it requires auditors...”
South Africa's financial disclosure form should be tailored to the country's specific context, corruption challenges, and scale, rather than directly adopting maximalist international best practices.
“In high income countries they do not have this kind of disclosure requirement and that might be the case because the level of corruption and the kinds of challenges that they deal with do not necessarily warrant that kind of level of disclosure and invasion of privacy... these issues should always be tailored to your specific context, to your specific challenges, the scale of the corruption issue that you have in a country.”
The recent StAR report assesses South Africa's financial disclosure form and e-disclosure system, identifying omissions and priorities to improve them according to international standards and good practice.
“This was an assessment conducted at the request of the Department of Public Service and Administration to both look at the form as well as the e-disclosure system and how it functions currently... to assess the current form against these international standards and good practice to determine what are some of the omissions in the South African context currently that should be considered and some of the priorities.”
A lifestyle audit or substantive investigation can be triggered by a whistleblower or interdepartmental complaint about suspected suspicious activity, highlighting the importance of the e-disclosure system and integrated databases for verification.
“One of the issues that can trigger a more substantive investigation such as a lifestyle audit is, for example, a whistleblower complaint or say an interdepartmental complaint that they suspect that there is maybe something suspicious happening with an individual that might warrant a more substantive investigation... this is also a core part of the verification process and why verification is so important... good practice is to also...”
False disclosure is treated as a criminal offence in many jurisdictions, but South African public service currently only uses disciplinary processes that are not sufficiently persuasive to deter false disclosures.
“In many cases where you will find that false disclosure itself is regarded as a criminal offence ... we do not have the same kind of sanctions in the public service regulations ... you have very little persuasive measures to deter people from submitting false disclosures.”
Currently, the sanctions for submission of false or incomplete disclosures in South Africa lead to ordinary disciplinary processes without clear consequences or severity scale, resulting in uncertainty for public officials.
“In the current system, this would be an ordinary disciplinary process ... you do not know how you get punished or whether you will be punished if you do not comply with the rules.”
Current sanctions for false or incomplete disclosures rarely involve criminal or strong disciplinary action, thereby limiting deterrence.
“Currently we do not have any kind of criminal or strong disciplinary sanctions for if we do find some kind of violation. You would just send that to a disciplinary process. So in effect you have very little persuasive measures to deter people from submitting false disclosures.”
A disciplinary process may be triggered if false statements are made on disclosure forms, leading potentially to criminal conduct investigation.
“If you were to lie on your disclosure form, perhaps the worst that can happen to you is that you go through a disciplinary process and it might trigger an investigation coming out of that to start looking into the criminal conduct.”
The document titled 'How to Put in Place Effective Sanctioning Provisions for Financial Disclosure Related Violations' provides comparative examples of sanctions from other countries to guide sanctions for disclosure violations.
“We have in this document, a few tables that provide examples from different countries on what this can look like legally to very particularly specify, for example, what the offence is for non-disclosure or for late submission.”
False or incomplete disclosure is a relatively low bar criminal offense in many jurisdictions, but verification processes seek to find undisclosed assets and require explanations for discrepancies.
“False disclosure itself is regarded as a criminal offence and it is a relatively low bar to be able to prove that ... Incomplete disclosure ... effectively there are assets that you have not disclosed ... when we are in that verification process, we compare this to what we have on records elsewhere and we find a particular instance where you have not disclosed a vehicle or house. You might have opportunity to explain why, what those discrepancies are.”
The form's treatment of assets used beneficially by a public official but legally owned by third parties is a significant issue highlighting the gap in disclosure regarding beneficial ownership.
“modern phenomenon where something is neither an asset, nor a loan in the true sense, but a public official has the right of use of an asset, either a house or a car, that belongs to somebody else ... this relates to our definition of beneficial ownership ... beneficial use ... joint ownership ...”
Understanding income on the financial disclosure form should include a continuous narrative of the source, value, acquisition, and disposition of assets over time, not just accounting revenue and expenditure for a particular year.
“we need a kind of constant narrative throughout the financial disclosure form to understand the origins of each asset when it was purchased, what its value was at purchase, but also in many cases when it was disposed of ... we need to understand flow of financial means and what this looks like over time ... not necessarily talking about this in the same way as accounting practice”
The current financial disclosure forms are essentially a list of assets owned without accounting for changes over time or other beneficial interests, limiting their effectiveness for oversight and investigations.
“our current approach in the financial disclosure form is essentially a list of assets that one owns ... it is not intended to understand these changes over time ... to understand the additional kind of interest ... based on good practice internationally ... strengthening downstream processes to detect potential anomalies and to support investigations”
It is important to find a balance in improved disclosure requirements that captures full circumstances while remaining practical and understandable for compliance.
“I think this is an important question. I think you do have to find a balance between...”
The current framework addressing corruption prevention in South Africa is fragmentary and incremental approaches have reached limitations; a substantive overhaul with a dedicated corruption prevention agency is needed.
“a lot of the fragmentation and weaknesses that we see in the current framework are a result of incremental attempts to improve the system ... the system in its current form has reached the limit of incremental improvements and has reached a point where you need the more substantive overhaul of how these functions are dispersed”
The only red flags currently automated in the system relate to other remunerative work and gift declarations; comparative verification with prior years requires manual review.
“The only red flags that they currently have in the system is around other remunerative work and gift declarations”
Public disclosure requirements for family members who are outside of the public service aim to respect their privacy.
“we are saying in the Sri Lanka example that you often have redacted sections where you would not extend this necessarily, the public disclosure requirements to family members that are outside of the public service to respect their privacy.”
In international practice, there is often a requirement for initial disclosure by family members, which may be relevant in the South African context though there is uncertainty about the legal implications.
“I think that is a fair question. I do not think I would be able to confidently speak to...in international practice, I think it is something that you often find and I think there is a strong argument to be made for why it is relevant in the South African context.”