Up to date and auditable

Data should be kept up to date and historical records maintained

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

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.


Resources

Implementation Guide
OpenOwnership · May 2020

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

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