Sufficient detail

Beneficial ownership disclosures should contain sufficient detail to allow users to understand and use the data

  1. Key information should be included about the beneficial owner, the disclosing company, and the means through which ownership or control is held.
  2. Clear identifiers should be used for people and companies.
  3. Politically exposed persons should be clearly identified within the data.
  4. Where beneficial ownership is held indirectly through multiple legal entities, sufficient information should be published to understand full ownership chains.

Collecting and publishing key fields of data about the beneficial owner and the disclosing company enables users to accurately interpret the data and determine which individuals and companies the disclosure refers to. Collecting and publishing the means through which ownership or control is held further adds to the utility of the data by enabling users to understand how beneficial ownership is operating. This information can be important when investigating suspected cases of money laundering or corruption.

Having clear identifiers (such as registration numbers for companies and taxpayer numbers for people) makes it possible to match disclosures about the same people or companies and distinguish different people with the same name or similar details. Being able to match and disambiguate is important; for instance, when entities emulate the names of respectable companies in order to obfuscate ownership in due diligence processes. Users of the data should be provided with enough information to allow them to do this, and match the information with other datasets.

To strengthen the utility of beneficial ownership transparency as an anti-corruption tool, PEPs should be clearly identified, as they hold positions or have relationships that can be abused for the purposes of laundering illicit funds, corruption or bribery, and therefore have higher risks associated with them.

Where ownership or control is held indirectly through multiple entities, disclosure of intermediate steps in a chain is helpful. It provides detail about how beneficial ownership is operating and enables data to be joined up from different sources. The ability to link beneficial ownership information transnationally is essential to realising its full potential to expose networks of illicit financial flows and support robust and efficient due diligence in the global economy.


Resources

Data Protection And Privacy In Beneficial Ownership Disclosure

This is a research report from OpenOwnership, The B Team and The Engine Room in which we consider the legal implications of public beneficial ownership data to the public, evaluated from both the perspective of the companies holding that information and the authorities requiring it to be disclosed publicly, and the relationship with data protection and privacy laws.

View document
Example Paper Forms for Collecting Beneficial Ownership Data

This document provides example forms to guide officials tasked with developing paper forms to collect beneficial ownership information.

View document

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