Last updated: July 2021
Data should be kept up to date and historical records maintained
- Initial registration and subsequent changes to beneficial ownership should be legally required to be submitted in a timely manner, with information updated within a short, defined time period after changes occur.
- Data should be confirmed as correct on at least an annual basis.
- All changes in beneficial ownership should be reported.
- An auditable record of the beneficial ownership of companies should be available by dating declarations and storing and publishing historical records, including for dormant and dissolved companies.
Keeping data up to date is crucial for increasing trust in the accuracy of beneficial ownership data and the effectiveness of disclosure regimes. Requiring the timely submission of changes to ownership data or details of natural or legal persons increases the confidence that the data is current. It also reduces the risk that the beneficial ownership of a legal entity can be misrepresented during a lengthy submission window.
Requiring data to be regularly updated, and for those updates to include all changes that occurred since the last declaration, removes the potential for companies to disguise short term changes in beneficial ownership. This closes a loophole that would otherwise enable actors to circumvent disclosure of all persons that have held beneficial ownership of the company.
It is important to keep historical information about companies, as this can help uncover links that are not immediately evident from current information. For example, keeping and publishing historical records prevents an entity from obscuring its identity by changing its name, or a beneficial owner to hide by reincorporating. Historical and auditable records are critical for law enforcement to verify ownership claims against historical records. Historical changes can be referred to during investigation even where the accuracy of data is in question, and can provide evidence of “who knew what when” to assess, for instance, whether due diligence was undertaken effectively at a particular point in time.