Early impacts of public beneficial ownership registers: Ukraine

Overall impact

Ukraine was the first country in the world to require companies to disclose information about their ultimate beneficial owners and to make this information publicly accessible. It was among the first to implement a central and public BO register. Having a public BO register means that law enforcement, businesses, journalists, and citizens around the world can access information on the BO of companies in Ukraine.

Ukraine’s experience also exemplifies the importance of making BO data public, in line with the recommendation set out in the Open Ownership Principles for Effective Beneficial Ownership Disclosure (OO Principles) that sufficient data should be freely accessible to the public to maximise its potential impact.[77] Without a public register, evaluations of the data like the one undertaken by the AntAC would not be possible. This type of analysis creates accountability for companies to accurately report BO data and for the government to enforce the law’s implementation. Public access is key for widespread third-party use of data beyond authorities, which, as Ukraine’s experience shows, can help drive up data quality and increase impact.[78] Public data, despite its accuracy limitations, can help anti-corruption activists shine light on relationships and pathways of influence. Further work on verification and validation will help to ensure that the USR is a better reflection of the true nature of ownership and control in Ukraine’s economy.

If Ukraine continues to build on its record of ambitious commitment to BOT, its experience will show how the utility of BO data can be further enhanced when it is available in a well-structured format that allows it to be easily analysed and linked with other datasets. Under the 2020 AML Law, the USR should have better-structured data, be more up to date, and provide better visibility of the full ownership chains of companies. Critically, unique identifiers should allow data users to more easily integrate Ukraine’s public registers by unambiguously identifying people and companies across datasets.[79] The reporting of ownership structures should also make it easier to spot links between entities and individuals that may otherwise remain hidden.

When BO data is structured and interoperable, it is also easier to verify and a greater range of verification mechanisms can be used.[80] As the data quality improves, it will be possible to perform longitudinal analysis of the utility of BO data at different points of maturity. However, the realisation of these benefits depends on continued progress. The case studies presented above demonstrate that the limited data that is available in the USR has some utility, but the register is far from having reached its potential impact. The full implementation of the government’s 2021 reporting requirement updates and meaningful progress on data verification remain vital.