A/HRC/28/60 proposed that the sustainable development goal on illicit financial flows should incorporate the target to “reduce illicit financial flows from trade misinvoicing by 50 per cent”, noting that the current proposal by the Open Working Group to “reduce significantly illicit financial flows” or to “strengthen recovery of stolen assets” leaves it very vague as to what each State or actor would have to achieve by 2030. GFI argued that selecting tax and traderelated illicit flows as a target would focus on the majority of illicit financial flows, could be measured using official government statistics, would complement transparency initiatives already under way, enhance domestic resource mobilization and tax revenue and ensure that a far larger amount of capital would remain in developing countries. 51 72. Alex Cobham has suggested specifying three targets aimed at curbing illicit financial flows through enhanced transparency and exchange of tax information. His proposal is to: (a) Reduce to zero the legal persons and arrangements for which beneficial ownership information is not publicly available, in order to eliminate the potential for anonymous ownership of companies, trusts and foundations; (b) Reduce to zero the cross-border trade and investment relationships between jurisdictions where there is no bilateral automatic exchange of tax information, in order to prevent hiding of offshore assets and income streams; (c) Reduce to zero the number of multinational businesses that do not report publicly on a country-by-country basis, in order to expose major misalignments between the distribution of profit and the location of real economic activity. 73. Cobham argued that the strength of such targets would be that data could be collected to highlight to what extent each jurisdiction had met its responsibilities, so that accountability for financial secrecy affecting others could be properly monitored and tracked over time against objective criteria rather than vague political promises.52 74. The Independent Expert is of the view that the targets and indicators suggested by GFI and Cobham would be essential to operationalize and track progress in implementing a rather unspecified inspirational goal of “reducing significantly illicit financial flows”, that may easily fall victim to a lack of specification as to who should be responsible and held accountable for its implementation. However, such targets may need to be complemented by other indicators that would allow the tracking of progress in asset recovery efforts and the curbing of corruption and crime-related illicit financial flows.53 Consideration should also be given to indicators that would ensure that human rights are fully integrated into national and international efforts to curb illicit financial flows. Therefore, additional targets relating to the protection of witnesses and whistleblowers, the implementation of due diligence procedures by financial business and service providers, and investigative and prosecutorial efforts in relation to tax evasion and corruption should be considered. 51 52 53 22 Tom Cardamone and Dev Kar, “Benefits and costs of the IFF targets for the post-2015 Development Agenda”, working paper (4 August 2014), available from www.copenhagenconsensus.com/sites/default/files/iff_perspective_-_cardamone_kar.pdf. Alex Cobham, “Benefits and costs of the IFF targets for the post-2015 development agenda” working paper (4 August 2014), available from www.copenhagenconsensus.com/sites/default/files/iff_assessment_-_cobham_0.pdf. Angela Me, “Benefits and costs of the IFF targets for the post-2015 development agenda”, working paper (30 July 2014), available from www.copenhagenconsensus.com/sites/default/files/iff_viewpoint_-_me_0.pdf.