Beneficial ownership disclosure workbook
How to use this resource
This booklet provides fictional company ownership and control scenarios. Each scenario is described with a diagram and narrative, alongside some ‘Points for consideration'. These scenarios are designed to help you explore the extent of information disclosed when a company (a 'declaring company') is required to make a beneficial ownership declaration.
The declaring company is assumed to be registered domestically. This domestic jurisdiction is designated by the fictional flag shown below.
See the Key for full details of the elements used in diagrams. There are various ways you can use the scenarios. You might use the ‘Points for consideration’ to approach each scenario. Alternatively, you may have particular issues that you wish to explore or explain, such as: what information about intermediary companies needs to be disclosed, or what is the impact of setting thresholds (see the ‘Example use of scenario’ below). Finally, you might take the scenarios and modify them (changing ownership levels, adding other persons etc.) to examine further issues. We provide an example scenario here with just one illustration of how it might be used in practice.
Example scenario
Narrative: Person 1 indirectly controls 40% of the declaring company. They do that via a 40% holding in the parent company, Company A. Company A is also domestically registered