Public Asset Integrity Group LLC Integrity · Accountability · Public Trust

Integrity, attribution and internal control in public asset disposition

Research, training, audit and governance for public and compulsory asset sales.

Public Asset Integrity Group develops methods and technical instruments that strengthen accountability, traceability and integrity across the lifecycle of public asset disposition.

Integrity

Protecting the integrity of the process.

Accountability

Establishing who is answerable for acts, decisions and the exercise of judgment.

Public trust

Strengthening confidence through transparent, traceable and accountable processes.

What may be done
Answered by procedural rules
What was done
Answered by the auction platform
Who answers for it
The layer this firm works in
The problem

Three layers of integrity. Two are well served.

Procedure

Rules of the sale, deadlines and award criteria define what may be done. Mature regulation, well developed.

Platform

Identity verification, bid logs and auditable trails record what was done. Growing capability, improving steadily.

Attribution

Neither, by itself, necessarily establishes who is individually accountable for the judgment exercised in between.

When the conducting function is distributed across entities, that attribution can become unclear. Our work is in that third layer.

The method

Six components, applied across the disposition lifecycle

Each component addresses one question an agency must answer before, during and after a public sale.

i

Risk identification

Thirty-seven indicators organised by lifecycle stage, so that the person conducting the sale consults only what applies at the stage in hand.

ii

Control mapping

Each risk point matched to the control that addresses it, with the supporting authority or framework stated and independently verifiable.

iii

Audit metrics

Seven quantitative measures computed against the agency's own historical series rather than an external benchmark.

iv

Training

Delivered to the people who conduct and oversee sales, organised by the stage at which each risk is encountered.

v

Governance protocol

Thirty internal controls across seven stages, with a segregation-of-duties matrix and a compensating regime for smaller agencies.

vi

Institutional implementation

A phased sequence with declared limits, calibration against real data, and periodic review of the thresholds adopted.

Technical instruments

Four technical instruments for public asset integrity and governance

Integrity Framework

Architecture of the method: six components, three methodological principles, and the anchoring of each to a federal instrument within its defined scope.

EN · PT

Collusion Indicators

Thirty-seven indicators by lifecycle stage, seven of them quantitative, with calibration criteria, an escalation protocol and six reference cases from federal prosecutions.

EN · PT · ES

Internal Control Protocol

Thirty controls across seven stages, with a segregation-of-duties matrix and a compensating regime for agencies too small to segregate fully.

EN · PT

Attribution & Control

Technical project and engineering specification for a system that records observations as they occur and ties each one to a determinate person.

EN · PT
Research foundation

The method rests on published work

Five working papers are deposited with the Social Science Research Network. One is a revised English version of a previously published journal article. The research record also includes two articles published in Revista Jurídica UNICURITIBA, a double-blind peer-reviewed indexed journal, and one article in Consultor Jurídico.

Who May Sell the Public's Property?

Auctioneer accountability as a candidate control variable in the disposition of government assets · SSRN 7239219
Read on SSRN

Screening for Collusion by Stage, Not by Type

A lifecycle-organised instrument for public asset disposition · SSRN 7303918
Read on SSRN

Office, Function and Attribution

On the normative designation of the conducting agent in electronic public asset disposition · SSRN 7324578
Read on SSRN

What a Binary Column Cannot Capture

Regulatory architecture and the attribution of responsibility in U.S. auctioneer licensing · SSRN 7342938
Read on SSRN

Historical Evolution of Auctions and Public Sales

Delegated agent of public power · SSRN 7317599 · Revised English version of the article in Revista Jurídica UNICURITIBA, v. 3, n. 83, 2025
Read on SSRN
Normative anchoring

Mapped to United States federal instruments

GAO Green Book
Standards for internal control in the federal government, 2025 revision
OMB Circular A-123
Management's responsibility for internal control, revised March 2026
FAR Subpart 3.3
Reports of suspected antitrust violations, within federal acquisitions
Federal Management Regulation
41 C.F.R. Chapter 102, personal property management
NIST CSF 2.0
Cybersecurity outcomes across six functions; the framework states outcomes rather than prescribing how they are achieved

Each instrument is applied within its own defined scope. References to United States federal standards and agencies are made for methodological and research purposes. No affiliation, sponsorship or endorsement is implied.

Services

Three lines of work

Training

Lifecycle-based integrity instruction for the people who conduct and oversee public sales.

  • Delivered in person or remotely
  • Participant manual and case material
  • Adapted to the agency's own regime

Integrity audit

Retrospective review of an agency's disposition record against seven calibrated metrics.

  • Calibrated against the agency's own series
  • Findings stated with the metric that produced them
  • No scoring, ranking or risk classification

Governance protocol

Adoption of the internal control protocol as an agency rule, with segregation of duties and attribution architecture.

  • Thirty controls across seven stages
  • Compensating regime where full segregation is impractical
  • Configurable by regime, not imposed as fixed rule
Institutional audiences
Government agencies State surplus property programs Courts and judicial administrators Auction platforms Public asset managers Compliance and oversight professionals
Institutional engagement

Technical dialogue with public-sector practitioners and institutions

Public Asset Integrity Group engages with practitioners, regulators and institutional stakeholders to examine the application of its integrity, attribution and internal-control framework across different public asset disposition environments.

Request the executive brief
Founder

Built from practice, not from a desk

Gustavo Cristiano
Samuel dos Reis
Founder and Managing Member
  • Official Public Auctioneer since 2008
  • Registered in São Paulo, no. 790, and Santa Catarina, no. 407
  • President, National Association of Judicial Auctioneers
  • President, São Paulo State Auctioneers' Union
  • Director of Institutional Relations, national auctioneers federation
  • Member, Brazilian federal working group drafting the statute that will replace the 1932 auction law
  • Approximately 5,000 auction proceedings conducted

Eighteen years conducting judicial and extrajudicial auctions in Brazil under a regime in which the person conducting the sale answers personally for the acts performed and certifies what occurred.

In 2020, as a named petitioner together with the national association he presides over, he brought a proceeding before Brazil's National Council of Justice on who may conduct judicial sales when they take place online. The decision was unanimous, and the Federal Supreme Court later declined to disturb it.

The control points in this method were initially derived from that operational experience, and were subsequently examined against the relevant literature and mapped to United States federal instruments.

Institutional timeline

From practice to method to firm

2008
Licensed as an Official Public Auctioneer
São Paulo State Commercial Registry, no. 790
2019
President of the national association of judicial auctioneers
2021
Unanimous decision on who may conduct online judicial sales
Brought as a named petitioner before the National Council of Justice
2024
Appointed to a Brazilian federal working group
Alternate in 2024, full member from 2026, on the statute replacing the 1932 auction law
2025 – 2026
Research and publication
Five working papers, two peer-reviewed articles and four technical instruments
2026
Public Asset Integrity Group LLC formed in Florida
Together with the technical project and engineering specification for the attribution and control system
Contact

Enquiries and technical briefings

Office
Kissimmee, Florida, United States
Email
gustavo.reis@me.com
Telephone
+1 407 212 8626
Entity
Public Asset Integrity Group LLC, a limited liability company formed in the State of Florida

What you can ask for

Write with the subject line that matches your interest. Materials are provided at no cost.

  • A technical briefing for your agency or firm
  • The executive brief and complete documentation
  • Research materials and working papers
  • Discuss institutional application and technical cooperation