The Global Coalition to Fight Financial Crime (GCFFC), as part of its objectives to promote more effective information sharing between public and private entities, and to propose mechanisms to identify emerging threats and best practice approaches to more robust controls against money laundering, believes that all actors fighting financial crime should have instant access to high quality, highly usable beneficial ownership (BO) data. The use of anonymously owned legal entities – through shell companies, trusts, or other legal constructions – for hiding the proceeds of crime as well as its owners are well documented. However, international standards to date fall short of generating data that is useful and readily available for all law enforcement agencies, obliged entities and other actors fighting financial crime.

In this short paper the GCFFC are adding its voice to close gaps that have been open for far too long. We believe in short that:

  • BO should be clearly and robustly defined in law, with sufficiently low thresholds used to determine when ownership and control is disclosed
  • BO disclosures should comprehensively cover all relevant types of legal entities and natural persons
  • BO disclosures should contain sufficient detail to allow users to understand and use the data
  • Data should be collated in a central register
  • Data should be accessible to all actors fighting financial crime
  • Data should be structured and interoperable
  • Measures should be taken to ensure data is verified
  • Data should be kept up to date and historical records maintained
  • Adequate sanctions and enforcement should exist for non-compliance


The Global Coalition to Fight Financial Crime brings together different parts of the anti-financial crime ecosystem to work towards the establishment of global standards, built on public-private cooperation, to complement and make more effective current regional safeguards. 

Thibault Jacobs and Niamh Griffin


Important note: For the avoidance of doubt, this paper has not been approved, supported or endorsed by the Institute of International Finance who are conducting their own review and expect to have their own members position on this issue in due course. The GCFFC similarly neither supports nor endorses any IIF position in this regard. 

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