Up to date and auditable

Data should be kept up to date and historical records maintained

  1. Initial registration and subsequent changes to beneficial ownership should be submitted in a timely manner, with information updated within a short, defined time period after changes occur.
  2. Data should be confirmed as correct on at least on an annual basis.
  3. All changes in beneficial ownership should be reported.
  4. An auditable record of the beneficial ownership of companies should be created by dating declarations and storing historical records.

Keeping data up to date is crucial for increasing trust in the accuracy of beneficial ownership data and the effectiveness of disclosure regimes. Requiring the timely submission of changes to ownership data or details of natural or legal persons increases the confidence that the data is current. It also reduces the risk that a legal entity can be misrepresented during a lengthy submission window, thereby improving trust between businesses.

Requiring data to be regularly updated, and for those updates to include all changes that occurred since the last declaration, removes the potential for companies to disguise short term changes in beneficial ownership. This closes a loophole that would enable actors to circumvent disclosure of all persons that have held beneficial ownership of the company.

It is important to keep historical information about companies, as this can help uncover links that are not immediately evident from current information. For example, keeping historical records prevents an entity from obscuring its identity by changing its name, and allows for investigations in complex legal cases. Making available supporting information, such as the date when a beneficial ownership declaration was made, can further help users judge whether they trust the information and provide evidence of “who knew what when” in cases such as investigating whether due diligence was undertaken effectively at a particular point in time.


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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