Improving beneficial ownership transparency in Ukraine: Review and recommendations

  • Publication date: 29 March 2018
  • Authors: Zosia Sztykowski, Tom Mayne


Effective user engagement transforms beneficial ownership data collection from a tick-box exercise to a policy tool with a real impact on stemming corruption and creating a better environment for business. Restricted access (i.e. private) beneficial ownership registers are focused on engaging users in law enforcement and tax authorities, who can use the data to find information they need about individuals’ links to companies. The hoped-for impact is that this access will result in successful prosecutions and/or recovered tax revenue and assets, as well as acting as a deterrent for corrupt actions.

But when the data is open to the public, each of these effects is enhanced. Open access beneficial ownership data is available to a far greater number of users.[9] Additional users can serve to improve data quality by fagging missing information and inconsistencies, making it more difficult for corrupt individuals to hide behind lies or omissions. Beneficial ownership transparency gives more people and organisations a means to hold corrupt individuals accountable and a deterrent for unethical corporate behaviour. It is likely no coincidence that most of the 21 anonymous UK companies involved in the infamous Global Laundromat scheme dissolved just months before the UK’s beneficial ownership register came online.[10]

Public, open beneficial ownership data also has additional uses that are potentially transformative for a country’s society and business markets. When the data is published in an open, machine-readable format, it can be linked productively with other useful datasets, such as procurement data, sanctions lists, land registries, and so on. It can also be linked with beneficial ownership datasets from other jurisdictions, allowing users to track illicit financial flows across the world.

This is the premise behind Open Ownership, our project to build the first global register of beneficial ownership. Hand-in-hand with the register itself is the Beneficial Ownership Data Standard (BODS), which (when in widespread use) will allow more beneficial ownership data to be linked transnationally. The structured, open data format is essential to allowing large amounts of data to be analysed. This would be difficult, if not impossible, to do with data that is public but in non machine-readable formats such as PDFs and scanned picture files.

Crucially, public, open data on beneficial ownership opens up uses by the private sector that can result in a better environment for business and more efficient markets. With open beneficial ownership data, businesses can better vet prospective partners, clients or suppliers by requiring them to self-submit data, or use existing data to enhance due diligence and manage risk exposure, for instance in foreign direct investment. The business community has been vocal in their demand for beneficial ownership transparency in the B20 (representing the business community of the G20) and in other fora, as a means to ensure stable and fair markets that do not unfairly privilege the corrupt. EY’s 2016 Global Fraud Survey found that 91% of senior executives believe it is important to know the ultimate beneficial ownership of the entities they do business with.[11]

The flow from data production, to use, to impact is captured in this diagram of the open data value chain from the Open Data Charter.[12]

Open data value chain from the Open Data Charter

Rather than thinking of data sharing as a simple act of “opening up” information that is already there, the desired actions on the part of users, and response or impact in the world, must be considered from the primary stage of data production. The hoped-for outcome must be reflected in the design of the data sharing from the very beginning of the process to create a coherent flow.

Thus, it is by serving the needs of these users that the government of Ukraine will see the benefits of collecting and publishing beneficial ownership information. A public, open data register in Ukraine will engage a variety of users, not just in government but also in business and civil society. When the register and data are designed and maintained with user needs in mind, users will drive greater data quality, which results in more productive uses, in a feedback cycle that will have true impact for Ukrainian society.

In this report, we make recommendations tailored to the Ukrainian context on improving data quality and process to ensure the most useful data possible is generated. Below, we discuss the conversations that helped us to understand this context.


[9] In the UK, company data use has grown exponentially, to 10 million searches a day, since the data was made free and open (Email exchange between Companies House and Open Ownership, 3 March 2017).

[10] Harding, Luke, et al. “British banks handled vast sums of laundered Russian money.” The Guardian, 20 March 2017. News, 27 Oct 2014.

[11] EY, “Corporate misconduct - individual consequences.” 2016.

[12] Open Data Charter, “Anti-Corruption Open Up Guide Methodology.” July 2017.

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