Updated January 2023
Data should be kept up to date and historical records maintained
- Initial registration and subsequent changes to beneficial ownership should be legally required to be submitted in a timely manner, with information updated within a short, defined time period after any changes occur.
- Data should be legally required to be periodically confirmed as correct, on at least an annual basis.
- All changes in beneficial ownership should be legally required to be reported.
- Information should be kept for a reasonable and specified number of years, including for dormant and dissolved corporate vehicles.
A beneficial ownership register is a record of information that builds up over time and reflects a timeline of statements about ownership and control. New information about the ownership and control of a corporate vehicle supersedes older information as shares are sold, contracts are signed, company rules are updated, and new entities are incorporated.
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; reduces the risk that the beneficial ownership of a corporate vehicle can be misrepresented during a lengthy submission window; and contributes to meeting the requirements of the Financial Action Task Force (FATF) Standard.
Requiring data to be regularly updated, and for those updates to include all changes that occurred since the last declaration, enables auditability and removes the potential for corporate vehicles to disguise short-term changes in beneficial ownership.
It is important to keep historical information, as this can help uncover links that are not immediately evident from current information. For example, keeping and publishing historical records prevents an entity from obscuring its identity by changing its name, or a beneficial owner to hide by reincorporating. Historical and auditable records are critical for law enforcement to verify ownership claims against. Historical changes can be referred to during investigation even where the accuracy of data is in question, and they can provide evidence of “who knew what when” to assess, for instance, whether due diligence was undertaken effectively at a particular point in time. A publication policy which explains, for instance, why particular information fields may be redacted from declarations after a certain date, will help data users interpret the information.
