Summary of Open Ownership Recommendations, December 2019
In December 2019, Open Ownership provided Armenia with an interim briefing to consolidate the initial findings of the scoping review that relate to the extractives sector pilot. It is intended to inform the development of the regulatory framework, software systems and business processes for collecting and publishing beneficial ownership data for extractives companies. A summary of the recommendations from this report are outlined below:
Regulations and Disclosure Forms
1. Clarify the scope of the disclosure requirements so that they clearly describe which companies and persons that are connected to the disclosing company need to be included in the declaration.
2. Remove or lessen the requirements on collecting data on affiliated persons for this pilot.
3. Simplify the requirements to disclose information about intermediate entities in ownership chains for this pilot.
4. Provide guidance to companies to assist them with completing the form.
5. Consider whether the list of required data should be extended to include reasons - given by the declaring company - for any gaps in the disclosure.
6. Within the form, indicate which fields of information will be published publicly, and which will be used for internal purposes only.
Software system to collect and store beneficial ownership data
7. Use an agile development process to enable rapid development of the database, supported by iterative improvements.
8. Clarify the level of integration required with Armenia’s e-register by the end of the three months.
9. Ensure that data is structured to reflect the statement model used by the Beneficial Ownership Data Standard.
10. Incorporate a known transliteration system for converting information between Armenian, Cyrillic, and Latin alphabets.
Business processes to test and operationalise disclosure in extractives
11. Test the draft forms with one or more extractives companies that will be required to disclose.
12. If initial disclosures are made manually, convert as much of the data as possible to a structured format for publication.