Beneficial ownership transparency in Liberia

Methodology and Report Structure

This report contains our assessment of the beneficial ownership regime in Liberia and analyses current and planned reforms using the framework of the Open Ownership Principles. The OO nine Principles of Effective Beneficial Ownership Disclosure provide a framework for implementing [1] comprehensive beneficial ownership transparency (BOT) reforms, and assessing and improving existing disclosure regimes. They seek to generate actionable and usable data across the widest range of policy applications of BO data.

The Principles describe a range of policy, legal, systems, data, and technology characteristics that support publication of easy-to-use, accurate, and interoperable BO data. These Principles were developed through OO’s work developing the Beneficial Ownership Data Standard (BODS) and supporting almost 40 countries to advance beneficial ownership transparency (BOT). The implementation of the Principles enables countries to meet and exceed relevant aspects of the EITI, FATF and other international standards for disclosure.

For each Principle, we have provided a short analysis of how Liberia’s disclosure regime and plans for BOT reforms compares to the Principle identified. In our analysis, we have taken into consideration that Liberia is in the early stages of its journey to implementing BOT reforms. We highlight practical recommendations for how the country could further strengthen its policies and processes, and advance Liberia’s BOT implementation during the first two years of the OE programme.

The information contained in this report was obtained from desktop research and comprehensive review of the available laws and regulations on beneficial ownership in Liberia. The specific laws and documents that formed the basis of our analysis are:

• The 1986 Constitution of the Republic of Liberia
• Freedom of Information Act 2010
• Title 5, Associations Law (as amended) April 2020
• Regulations published by the Ministry of Foreign Affairs in furtherance of the Associations Law of Liberia
• Petroleum (Exploration and Production) Act 2014
• Disclosure of Ultimate Beneficial Ownership Regulation 2020 (0003/LPRA/20)
• AML/CFT Regulations for Financial Institutions in Liberia
• Regulation on Enhanced Due Diligence in the Provision of Financial Services for Politically Exposed Persons (PEPs)
• Beneficial Ownership Roadmap 2016 by LEITI MSG

To validate the findings from our independent research, we undertook in-person consultation at the LEITI office in Monrovia, Liberia, with key stakeholders, including LEITI, the LBR, LRA, LPRA and the FIU (members of the OE Steering Committee). Members of the LEITI MSG made context-specific contributions to our findings, provided more information about the BO disclosure regime in Liberia and imminent plans for reform, and offered insights on the government’s preferred approach on specific aspects of BO implementation. These consultation sessions took place on 14 and 15 April 2022; a schedule of the participants can be found on the Schedule of Stakeholders Consulted.

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