Insights from the United Kingdom’s People with Significant Control register
2. Research objectives
This research emerged from Andres’s deep curiosity about BO and complex corporate structures, combined with Maria’s expertise in data analysis and BO systems. Together, we set out to achieve three key objectives:
- to explore policy-relevant aspects of beneficial ownership, with a focus on the dynamics and complexity of ownership structures;
- to identify outliers and anomalous patterns that could support further investigation by competent authorities; and
- to develop an analytical framework for exploring ownership structures across different contexts and jurisdictions, aimed at informing researchers and authorities in their assessments of risks associated with ownership networks.
2.1 Exploring key aspects of policy reform
We explore crucial elements of BO policy reform by analysing how ownership interests, thresholds, and complexity manifest in practice.
Beneficial ownership interests
A clear and comprehensive definition of beneficial ownership should capture all relevant forms of ownership and control, both direct and indirect. [2] Such clarity is essential in order to prevent exploitation of disclosure frameworks and to strengthen overall transparency. Ownership should be understood to include the right to use, enjoy, and derive benefit from a legal vehicle or its assets. Capturing the full spectrum of control and benefit helps close loopholes that could otherwise obscure the true nature of ownership.
In line with this definition, our analysis investigates how different types of ownership and control interests are distributed, both individually and in combination (e.g. when an individual holds multiple interests in the same entity, such as shareholding and voting rights). Understanding these patterns offers valuable insights into how entities are controlled and owned within a jurisdiction, shedding light on the various mechanisms through which influence is exercised.
Beneficial ownership thresholds
Both the definition of beneficial ownership and the thresholds for BO disclosure are widely debated. The Financial Action Task Force (FATF) recommends a maximum threshold of 25%, encouraging countries to adjust it based on current risks of money laundering and terrorism financing. Similarly, the European Union applies a 25% threshold but allows for reductions (e.g. to 15%) in high-risk sectors. [3]
Civil society organisations generally advocate for lower or no thresholds to enhance transparency. Open Ownership does not promote a specific threshold but supports a risk-based approach with national policy goals, such as tackling corruption or money laundering. Lower thresholds reduce the risk of concealing relevant ownership or control, whereas extremely low thresholds may generate higher compliance costs without necessarily adding actionable insights. [4] For high-risk sectors, however, lower thresholds can close critical transparency gaps while maintaining a balance between regulatory burden and effective risk mitigation. [5]
The Tax Justice Network advocates for a no-threshold approach, requiring disclosure for all individuals holding at least one share, vote, or benefit. [6] This is also the approach used in Argentina. [7] Critics of this model argue that it would increase compliance costs for registries and financial institutions, as more beneficial owners would need to be identified and verified. However, the Tax Justice Network contends that such concerns are overstated. [8] Even under the FATF’s 25% threshold, it is necessary to identify and verify all individuals with any level of ownership or control. This is because direct and indirect ownership must be aggregated to determine who ultimately controls 25% or more. The underlying mapping effort is therefore required regardless of the reporting threshold. [9]
Some opponents claim that individuals with smaller stakes can still be captured through the inclusion of “other means of control”, a provision intended to capture situations where a beneficial owner controls or influences the decisions of a legal vehicle without holding a majority ownership stake. In response, the Tax Justice Network notes that assessing influence or special rights is often impractical without access to internal company documents. [10] Furthermore, it hypothesises that the majority of UK companies have a single beneficial owner or a very limited number of owners. This suggests that lowering thresholds would not significantly raise compliance costs. Since most beneficial owners are declared based on ownership rather than control, lower thresholds could more effectively expose hidden interests than relying solely on control-based declarations.
Building on this debate, our analysis examines the distribution of shareholding and voting-rights percentages, highlighting how different ownership patterns emerge under varying scenarios. By exploring these dynamics, this research sheds light on the practical implications of different threshold settings for transparency and control, offering a nuanced understanding of how thresholds can either strengthen or weaken the integrity of BO disclosures.
Beneficial ownership complexity
Corporate ownership structures can often be layered and opaque, providing avenues for beneficial owners to obscure their influence and evade scrutiny. [12] The Tax Justice Network has long called for stronger regulations to address these complex structures, since evidence shows these present a higher risk of misuse, particularly for illicit financial flows and tax evasion. At the same time, a 2020 Tax Justice Network study using Orbis data found that most companies maintain relatively simple ownership structures. [13] This finding supports the case for more granular disclosure requirements given that such reforms would predominantly affect higher-risk, complex structures without placing excessive burdens on the majority of businesses. [14]
This research tests this hypothesis using UK data to assess whether complex ownership is as rare as previously suggested. The analysis explores the prevalence of complex ownership models, their structural features, and the implications they pose for transparency and control. By unpacking these dynamics, the research offers deeper insights into how policy measures targeting ownership complexity can improve the effectiveness and integrity of BO disclosure regimes.
2.2 Detecting outliers
In addition to exploring aspects of policy reform, this research has also sought to identify outliers – that is, ownership structures that deviate significantly from typical patterns. These included entities that failed to register any beneficial owner despite legal requirements to do so; entities reporting an unusually high number of beneficial owners; and individual beneficial owners linked to an exceptional number of entities. Identifying such anomalies is essential for flagging potential risks, supporting enforcement efforts, and improving understanding of irregular ownership patterns which may be used to obscure control or influence.
2.3 Establishing an analytical framework
To support broader application of our findings, the project has also aimed to develop a replicable and scalable framework that can be applied across jurisdictions and datasets. This framework is intended for use by government authorities, researchers, activists, and other stakeholders working to improve beneficial ownership transparency (BOT). It supports both the exploration of key policy areas, such as ownership interests, thresholds, and complexity, as well as the detection of anomalous patterns within BO data. All analytical steps, visualisations, and results are documented in a structured Python notebook to facilitate reuse, allowing others to download, replicate, and adapt the methodology for their own purposes and contexts.
Footnotes
[2] See: Open Ownership, “Definition” in Open Ownership Principles for beneficial ownership disclosure (Open Ownership, updated 2023), https://www.openownership.org/en/principles/definition.
[3] See: FATF, Guidance on Beneficial Ownership of Legal Persons (FATF, 2023), https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Legal-Persons.html; Leyla Ates, Andres Knobel, Florencia Lorenzo, and Markus Meinzer, “Competition and Complementarity of EU and FATF Beneficial Ownership Transparency Orders” in I.J. Mosquera Valderrama, F. Heitmüller, J. Chaisse, and A. Christians, (eds.) Redefining Global Governance. Emerging Globalities and Civilizational Perspectives (Springer, Cham, 2025), 85–96, https://link.springer.com/chapter/10.1007/978-3-031-69793-7_7; European Commission, “Anti-money laundering and countering the financing of terrorism at EU level”, 2024, https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-eu-level_en.
[4] For more information on thresholds, see Figure 2 in this report: Tymon Kiepe and Peter Low, “Thresholds”, in Beneficial ownership in law: Definitions and thresholds (Open Ownership, 2020), https://www.openownership.org/en/publications/beneficial-ownership-in-law-definitions-and-thresholds/thresholds/.
[5] See: Kiepe and Low, “Thresholds”.
[6] See: Andres Knobel, “Roadmap to Effective Beneficial Ownership Transparency (REBOT)”, Tax Justice Network, 7 February 2023, https://taxjustice.net/2023/02/07/roadmap-to-effective-beneficial-ownership-transparency-rebot/.
[7] See: Andres Knobel, “Argentina finally has a beneficial ownership register. Now, it should make it public”, Tax Justice Network, 20 April 2020, https://taxjustice.net/2020/04/20/argentina-finally-has-a-beneficial-ownership-register-now-it-should-make-it-public/.
[8] See: Andres Knobel, Why beneficial ownership frameworks aren’t working – and what to do about it (Tax Justice Network, 2023), https://taxjustice.net/wp-content/uploads/2023/12/Why-beneficial-ownership-registries-arent-working-Tax-Justice-Network-Dec-2023.pdf.
[9] For example, if a company knows that Mary owns 40% of the shares, this information alone does not suffice to register the company’s beneficial owners. The company must also identify all direct and indirect owners of the remaining 60% to ensure that no one else holds more than 25%, and to verify if Mary has additional indirect ownership. BO laws require the disclosure of exact shareholding or control of each beneficial owner. Without this information, the company would only know that Mary owns at least 40%, but not her precise ownership.
[10] Knobel, Why beneficial ownership frameworks aren’t working, 13.
[11] Andres Knobel and Oliver Seabarron, “Exploring UK companies’ legal ownership chains to detect red flags and verify beneficial ownership information: Part 1”, Tax Justice Network, 6 July 2020, https://taxjustice.net/2020/07/06/exploring-uk-companies-legal-ownership-chains-to-detect-red-flags-and-verify-beneficial-ownership-information/.
[12] See: “What is beneficial ownership transparency?”, Open Ownership, n.d., https://www.openownership.org/en/about/what-is-beneficial-ownership-transparency/.
[13] See: Knobel and Seabarron, “Exploring UK companies’ legal ownership chains”.
[14] See: Andres Knobel, Complex Ownership Structures: Addressing the Risks for Beneficial Ownership Transparency (Tax Justice Network and Financial Transparency Coalition, 2022), https://taxjustice.net/wp-content/uploads/2022/02/Complex-ownership-chains-Reduced-Andres-Knobel-MB-AK.pdf.