Implementation of COSP Resolution 10/6 on Enhancing the Use of Beneficial Ownership Information to Strengthen Asset Recovery

Tracing beneficial ownership networks across borders

Understanding the links between national beneficial ownership transparency reforms, data usability and international data-sharing

This case study demonstrates insights in line with operative paragraph 2 of resolution 10/6, in which the Conference urged States Parties “to cooperate closely with one another, bearing in mind the need to provide one another the widest measure of international cooperation, in accordance with the United Nations Convention against Corruption and domestic law, to facilitate the efficient exchange of adequate, accurate and up-to-date beneficial ownership information in a timely manner.”

Understanding beneficial ownership data usability to unlock beneficial ownership transparency’s impact within and across borders

Lack of appropriate, effective and timely access to BO information has been one of the main challenges identified by Member States in analyses undertaken by UNODC in 2023 and 2024, and during the Intergovernmental Meeting on Enhancing the Use of Beneficial Ownership Information to Strengthen Asset Recovery, which was held from 14 to 15 April 2025 in Vienna, Austria.

Many countries have legal provisions that only allow domestic competent authorities and limited additional categories of domestic actors to directly access their BO registers. In doing so, governments may seek to minimize infringements on rights to privacy, protect national security or align with data protection laws. Governments can design various safeguards in line with principles of necessity and proportionality to achieve these legitimate aims. Yet, when such measures are not carefully designed, they may prevent the effective use of BO information, ultimately undermining other important goals shared by governments, such as tackling crime and generating public revenue by tracing IFFs across borders, identifying those who benefit from the profits and assets derived from illicit activities.

It is important to ensure these safeguards do not unduly prevent the effective use of BO information. Countries can draw on evidence about BO data use to develop legal frameworks that enable access to BO information and design data systems that facilitate the effective processing of such information.

Individuals and agencies who use BO information to analyze criminal activity and investigate and trace the proceeds of crime and IFFs often require following leads and studying patterns across multiple types and sources of information, and across jurisdictions. Many users face barriers to accessing information in a timely manner or accessing it at all. High costs to using BO data due to diverging details and formats of information across sources, as well as limited options to search and process information, further complicate efforts.

There are several key features that ensure that those using access points for BO information, such as central BO registers for legal vehicles, can retrieve the information they need and undertake essential analyses. These include:

• Effective and relevant search features, such as searching by the names of beneficial owners
• Provision of data in bulk, i.e. simple downloads of large volumes of data
• Availability of data via application programming interfaces (APIs), i.e. tools to allow different systems to communicate and access each other's data

Collecting and storing BO data in a structured way is a basis for these features. Providing supporting documentation also helps users better understand and interpret the data they can access. Well-structured data that is organized into separate fields and available in a machine readable format also facilitates verification. This makes data more reliable for users by improving its accuracy.

These data and system characteristics improve data usability and should be considered in both domestic BO registers and the transnational mechanisms that aim to facilitate information-sharing across borders.

Processing BO information from different jurisdictions, as well as across other relevant information sources such as sanctions and politically exposed persons lists, to understand the networks of relationships between individuals, legal vehicles and assets – or BO networks – also requires ways to connect and make sense of information held in various places. For example, it means being able to understand if records from different sources of information refer to the same person or legal vehicle (entity resolution). When different sources use reliable identifiers, such as tax identification, company incorporation and social security numbers, or open license identifiers such as the LEIs, to distinguish between different legal vehicles and individuals, it supports systems interoperability and simplifies entity resolution. Such identifiers for individuals are less likely to be used across borders due to their privacy-sensitive nature. Using a standardized way to structure sufficiently detailed information – including widely used data formats for common types of fields – reduces the amount of resources required to append and join information sources and makes it easier, faster and cheaper to identify links across and between them.

Understanding these features of BO data usability is essential to support effective data-use on a domestic level while also working towards enabling the effective use of information across borders. Aligning domestic BOT provisions across countries also supports users’ understanding of transnational ownership networks. Evidence-based frameworks exist to guide BOT implementing countries in identifying broad principles for effective laws and policies.

Data-sharing mechanisms and beneficial ownership data usability

In most countries implementing BOT reforms, the legal obligation to disclose certain information only applies to legal vehicles governed under domestic laws. Some countries also collect information about foreign entities and arrangements that have “sufficient links” with their jurisdictions – as per FATF Recommendations 24 and 25. For example, a number of countries have BO registers of foreign legal entities that own certain types of assets considered to have a high risk of money-laundering, such as the United Kingdom’s (UK) Register of Overseas Entities. As of 2025, no authoritative inter-governmental mechanism exists that combines BO information with other relevant datasets and information about people, legal entities and assets across borders at the global level. To address this gap and support anti-financial crime actors to build a comprehensive understanding of transnational BO networks, a number of mechanisms have emerged.

Access-upon-request means untimely access to information, hindering investigation

Access to information upon request

From mutual legal assistance in criminal matters to global and regional networks, mechanisms and agencies like the GlobE Network, the Egmont Group, the Asset Recovery Inter-Agency Networks or INTERPOL and regional equivalents, many multilateral mechanisms are open to law enforcement, judicial and investigative authorities and allow access to information from a large number of countries, which can be used as evidence in court or as cross-border intelligence. They are based on an access-upon-request model, and many provide electronic systems to streamline requests and securely exchange emails and documents. They also help authorities identify relevant contact points and information sources. For example, the GlobE Network with over 240 anti-corruption and law enforcement authorities from 132 Member States at the time of writing, offers its members tools such as the Directory of Member Authorities and Directory of Open Source Registries including BO registers, enabling members to identify competent counterparts, request information securely and access open-source data relevant to financial and corporate transparency for anti-corruption and law enforcement authorities. While the Network does not maintain its own databases, it provides a trusted operational platform for direct authority-to-authority communication.

While highly valued as collaboration channels and having led to impactful cases, authorities continue to report gaps in international measures to comprehensively meet their needs. Consultations with authorities have pointed to requests sometimes taking weeks or months to receive responses. As concluded by UNODC in 2024, “insufficient cooperation efforts, channels and mechanisms hinder the collection and exchange of BO data across jurisdictions.” Many international mechanisms are enabled by agreements, conventions and treaties that often include articles listing reasons for refusing assistance, which, although legitimate (e.g. national security), can hinder information-sharing. At the same time, some jurisdictions have also reported needing inter-agency agreements and written requests to access information in their own countries, thereby impacting their ability to fulfill international cooperation duties in a timely manner. Some smaller scale initiatives have addressed the timeliness issue of access-upon-request by developing tailored bilateral arrangements. For example, the “exchange of notes” between the UK and the British Overseas Territories empower law enforcement from these jurisdictions to receive responses within 24 hours, but is limited to a small number of jurisdictions.

Automatic exchange of information

The tax sector includes mechanisms that cover a large number of countries and is a unique example of the automatic exchange of large sets of information on a global scale. The Organisation for Economic Co-operation and Development’s (OECD) Automatic Exchange of Information (AEOI) mechanism requires tax authorities, who all receive information from financial institutions, to automatically share this information annually with counterparts in countries where bank accounts holders are tax residents. This automatic exchange of information allows authorities to receive information directly and is done in bulk to enable large-scale analysis. Exchanges occur through the Common Transmission System, a secure, encrypted platform that ensures confidentiality, data protection and technical interoperability between participating jurisdictions. However, this mechanism has also been criticized for its lack of inclusivity in countries with lower financial resources and technical capacity. The information received is also not uniformly up-to-date due to exchanges occurring annually, at different points in time for different jurisdictions. While only accessible to participating tax authorities, the design of this mechanism and its usability features offers a valuable model to consider solutions for the international exchange of BO for broader cooperation purposes such as to tackle corruption.

Direct and indirect access to information

Some mechanisms allow for direct access to national BO registers without needing to request specific information or set up legal agreements. Primary examples of this are central BO registers that make information publicly accessible and freely searchable, such as in Nigeria and the UK. When making structured information available in bulk or through APIs, these public registers allow data to be integrated into data-sharing platforms. Open Ownership’s prototype global register standardized and connected data from public registers and provided tools to support users in analyzing data from four jurisdictions. However, it only ever covered four countries, and the significant overhead associated with this work made it hard for a non-profit organization to sustain and scale up progress. A similar approach was suggested by Heads of States calling for a global BO register in their outcome document ahead of the 2025 Financing For Development Conference, and by other parties supporting the development of a global asset register. However, only a minority of countries make information available in ways that allow such integration into a transnational platform. Some commercial providers ingest BO data from publicly accessible registers even where these do not provide information in a structured format (e.g. through scraping [28]), but they can be unaffordable to many users. The OECD has proposed hosting a similar platform and connecting this information to real estate information for tax purposes as an alternative to the exchange of information.

The EU’s AMLD6 also provides a model of regional access, where a large range of anti-financial crime actors – from EU and national authorities, to obliged entities, non-governmental organizations (NGOs), academics and investigative journalists, can directly access BO information based on their legitimate interest to do so. While the EU develops further specifications which may clarify whether a single point of access to BO information from multiple Member States’ register will include entity resolution or not, it has stated that access will be to “the interconnected central [BO] registers,” which appears to be the Beneficial Ownership Registers Interconnection System (BORIS). EU authorities have “immediate, unfiltered, direct and free access” to all EU members’ BO information, and once civil society actors demonstrate their legitimate interest, they are able to access EU registers directly for three years. Access by these actors is particularly important to support the work of authorities. Research points to law enforcement’s insights highlighting that “officers involved in investigating grand corruption … recogniz[e] that … collaboration among much wider networks that include law enforcement, NGOs and the private sector” is critical.

Existing mechanisms have complementary strengths but more is needed to significantly lighten costs to users linking data across borders

Existing mechanisms include promising practices to support effective BO data use, but still have legal, technical and operational gaps which affect different aspects of data usability, including making advanced searches and analyses and performing entity resolution.

While global upon-request mechanisms offer valuable systems to streamline information requests, securely exchange information and support collaboration, they fall short in providing timely direct access to multiple datasets, necessary for effective BO data use. While only limited to the tax sector, the OECD’s Common Report Standard (CRS) offers valuable lessons by setting out a detailed and standardized way to structure the information exchanged under the AEOI and provides guidance to help users interpret it. The EU’s 2024 anti-money-laundering package states that BO information needs to be collected in a structured way, in a format defined by the EU institutions, standardized across jurisdictions and available in machine-readable format. While the AEOI facilitates the exchange of bulk data, the AMLD6 does not include specific requirements for data access in bulk or via APIs, and most of the upon-request global mechanisms only allow access to a single – or sometimes a batch of – records at a time. Effective search features also support various analyses, but many BO registers still have gaps in this area. For example, many do not allow searching by the names of beneficial owners, although broadly considered as highly valuable by users.

A lack of sufficiently detailed information, even in more sophisticated systems like AEOI, can make entity resolution more difficult to perform. For example, while providing satisfactory details on individuals and entities, certain attributes, such as dates of birth and tax identification numbers, are not mandatory in the CRS. The EU’s legitimate interest access regime plans for access to historical information, and its regulation mandates the collection of information on intermediary vehicles through which a beneficial owner exercises their interest on a legal vehicle, which suggests that information on wider BO networks may also be accessible. As of now, no plans have been published to interconnect EU registers by incorporating entity resolution processes for legal entities and people. Under AMLD5, data users who accessed BO data through the BORIS system had to undertake entity resolution themselves using other identifying attributes. Doing so requires standardizing information from different sources and often in different formats, which has been the biggest added value of many data-service providers given the time and cost associated with this process. Emerging discussions on how artificial intelligence may impact BOT reforms also emphasizes how machine learning algorithms can help contextualize and analyze data from BO registers and other datasets, while not being a replacement for investing in data quality at source.

The experience of federal administrations trying to join data organized differently at the sub-national level illustrates an alternative approach to commercial offerings in this area. For example, the federal governments of Canada and Mexico have seen value in using open standards – such as the Beneficial Ownership Data Standard – as guides to understand what usable datasets may look like, and explore contextualization for their jurisdictions.

While ensuring various datasets use common reliable identifiers is one element of standardization, which greatly supports their interoperability, examples of cross-border mechanisms that heavily invest in this are scarce. Initiatives such as the European Digital Identity Wallet offer harmonized identity verification to support entity resolution for individuals.

Conclusion

While global policy standards exist, BOT is implemented at the national level, and modalities of collecting and accessing BO information significantly vary across countries for a range of reasons, including diverging legal contexts. Unaddressed tensions between various national policy objectives such as anti-financial crime, national security and data protection mean that timely access to information is still a challenge for many data users. When data is available, in the absence of free, affordable and centralized access points to standardized BO information from multiple jurisdictions, investigative authorities and other anti-corruption and crime experts also spend considerable amounts of time and resources trying to piece information together. Ensuring national BOT reform and cross-border data-sharing initiatives are designed with data user needs in mind can guide decisions on how to ensure safeguards do not unduly limit BOT’s impact and design systems that enable the effective processing of BO data from multiple sources to understand transnational BO networks. A number of initiatives outlined in this document include promising and complementary features – such as cross-border trust, streamlined processes and direct access to structured and standardized data for a range of relevant actors – which could form a basis for testing more direct data-sharing approaches on a sub-regional or tailored basis.

Footnotes

[28]