Search for PEPs or companies that hold an extractive license or contract and for PEPs from the Ministry of Mines and Energy, Ministry of Environment and Sustainable Development and Congressmen and Congresswomen from the House of Representatives and the Senate of the Republic.


Click on the red dots to check the red-flags identified by the system, linking FD information, EITI Industry data and Public Procurement datasets.





Red Flags

The system will signal red flags in situations that are commonly linked to potential corrupt behaviour.

Conflict of interest alert

Where a PEP owns shares of a company that holds an extractive license/contract with the State.

Asset declaration form irregularity alert

Where a PEP’s asset declaration form indicates that he or she owns shares in a company but the section other incomes remains empty; or vice versa, where a PEP has declared other incomes but the sections to declare participation in entities or institutions; corporations, partnerships and/or associations; and economic activities of private nature remain empty in the form.

Red-flags found

Joining the Dots processed 1,3% of the PEPs asset declaration forms dataset. These are the red-flags found:

Politically Exposed Person Position Government Red Flag

Efraín José Cepeda Sarabia


Senado de la Republica

Potential Conflict of Interest: PEP owns shares in a State contracting company

Diela Liliana Benavides Solarte


Cámara de Representantes

Potential Conflict of Interest: PEP owns shares in a State contracting company

Edgar Jesus Diaz Contreras


Senado de la Republica

Potential Conflict of Interest: PEP owns shares in a State contracting company

Fernando Nicolás Araújo Rumié


Senado de la Republica

Potential Conflict of Interest: PEP’s relative is the legal representative of a State contracting company

Declared potential conflicts of interests

Public authorities and employees must indicate potential conflicts of interest in their asset declaration forms. In the following section, you will find the cases declared by the PEPs analyzed.

Politically Exposed Person Position Potential conflicts of interest declared by PEP

Carlos Eduardo Acosta Lozano

Representante a la Cámara

Un familiar en primer grado de consaguinidad, hace parte de la Junta Directiva de una entidad sin ánimo de lucro, Un familiar en segundo grado civil, es dueña de una Institución Educativa

Yamil Hernando Arana Padaui

Representante a la Cámara


Juan Nicolás Galarza Sánchez

Director Técnico, Código 0100, Grado 22 de la Dirección de Espacio Urbano y Territorial, empleo de libre nombramiento y remoción

Hermana y cuñado propietarios de empresa "Avance Urbano Proyectos y Construcciones Ltda" que hacen distintos tipos de remodelaciones, pero no realizan proyectos contructivos de vivienda.

Efraín José Cepeda Sarabia


Mi familia tiene intereses en el sector inmobiliario a través de la empresa Cepeda y Cia SAS, con 71 años de fundada. Parque industrial en el departamento del Atlántico, además actividad agropecuaria, sector ganadero e inversiones en finca raíz. Mi familia es socia de una empresa distribuidora de teléfonos celulares.

Joining the Dots with PEPs

The objective of the project ‘Joining the Dots with politically exposed persons (PEPs)’ is to enhance transparency related to beneficial ownership (BO) as well as to the interests and assets of public officials. More specifically, the goal is to support country authorities in enhancing the effectiveness of their Financial Disclosure (FD) systems and implementing BO disclosures, while ultimately contributing to their wider anti-corruption framework.

The project will achieve this by supporting users in systematically gathering, verifying and promoting the use for FD and BO data for anti-corruption purposes, developing a system that cross-matches existing datasets and generates red-flags to identify PEPs.

So far, in Colombia, we analyzed more than…

Asset declarations

EITI, Directorio Legislativo and IMF are teaming up to work on this project aimed to identify and mitigate corruption risks by ‘joining the dots’ with company owners and politically exposed persons. The project is part of the IMF Anti-Corruption Challenge.


Hidden beneficial ownership of companies and lack of oversight of assets held by politically exposed persons are factors that exacerbates the risks of corruption and tax evasion. Many governments have recognized the problem and expressed the need for better beneficial ownership information and financial disclosure systems.

Problem statement

Lack of simple, robust and practical tools to put together publicly accessible information and cross-check/verify data on beneficial ownership and financial disclosure of public officials.

Main objective

Support authorities in enhancing effectiveness of financial disclosure systems and implementing beneficial ownership disclosures, while ultimately contributing to their wider anti-corruption framework.

How to address the problem?

Through this project, we aim to identify corruption risks based on the level of involvement of PEPs in contracts/licenses granted by the government for the extractive sector.



EITI is the global standard to promote the open and accountable management of oil, gas and mineral resources. Guided by the belief that a country’s natural resources belong to its citizens, the EITI has established a global standard to promote the open and accountable management of oil, gas and mineral resources. The EITI Standard requires the disclosure of information along the extractive industry value chain from the point of extraction, to how revenues make their way through the government, and how they benefit the public, in order to strengthen public and corporate governance.

Directorio Legislativo

Directorio Legislativo is an independent, non-profit organization working to strengthen democracy and make law and policy-making in Latin America more transparent, representative and participatory. We achieve this by improving access to public information and through the creation of spaces for legislators and politicians to engage and be influenced by outside specialists, civil society and the public at large.

About IMF

International Monetary Fund

IMF is an organization of 189 countries working to foster global monetary cooperation, secure financial stability, facilitate international trade, promote high employment and sustainable economic growth, and reduce poverty around the world. Its primary purpose is to ensure the stability of the international monetary system.

IMF Anti-Corruption Challenge

Aims to support the development of new and innovative approaches on the following theme: how might we create behavioral change and increased transparency to enable good governance and tackle corruption in the public sector?

Open data

Our main challenge was related to data availability: closed formats datasets, asset disclosure forms in diverse formats (handwritten, PDF, scan and photographs), lack of beneficial ownership data, operability of links, delivery of information from public agencies and denial of public access to certain data. However, we overcame these obstacles by manually uploading the information to set up our database and run our cross-checks.

Data availability and open sources formats are essential to enforce the human right of access to public information.