Comprehensive coverage

Disclosure should comprehensively cover all relevant types of legal entities and natural persons

  1. All relevant legal entities and arrangements, and all relevant natural persons (i.e. people), should be included in disclosures.
  2. Any exemptions of certain types of entity from the disclosure requirements (such as for listed companies) should be clearly defined and justified, and information on the ownership of such entities should be collected elsewhere with comparable levels of quality and access.
  3. Particular attention should be given to the disclosure requirements relating to ownership by state owned enterprises (SOEs).

Comprehensive coverage is important because if certain types of legal entities and arrangements are not covered, potential loopholes form that can be exploited for illegitimate purposes. Understanding where and how SOEs are involved in ownership or control of reporting companies can be an important element of understanding corruption risk. Due to their connections to PEPs, involvement of SOEs in an ownership chain can be an important piece of information to consider within due diligence and investigations.


Beneficial Ownership Policy Reviewer

There are a number of aspects that need to be considered when designing a legal framework for beneficial ownership transparency. The Policy Reviewer works through these aspects, and guides implementers to identify specific decision points around what data is to be collected and what is to be published. The Policy Reviewer does not prescribe a particular policy approach, but is designed to help implementers to explore the relevant areas and identify legal changes required for beneficial ownership transparency.

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Implementation Guide

A step-by-step guide to implementing beneficial ownership transparency.

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