Open Ownership is pleased to contribute to the public consultation on revisions to the FATF Recommendation 24. Open Ownership recommends that FATF makes central BO registries a requirement as part of the multi-pronged approach under Recommendation 24. A central registry is the most effective way to ensure competent authorities, obliged entities and all other actors fighting financial crime have timely access to accurate BO data. Registrars should be primarily responsible for ensuring the verification of BO data in these registers, although all users of the data have a role to play in improving data accuracy. In order to address some of the current challenges, FATF should set minimum standards for key attributes of central registries and clearly outline the role regulators should play. This will lead to accurate, usable data, which is fundamental in fighting financial crime, but in itself does not automatically lead to data use and impact. Governments should take a proactive approach to increasing the capacity for proactive data use amongst all actors fighting financial crime. Central registries have been and are being implemented in major financial centres, and it is here that the evidence must be gathered and the models developed for other countries to emulate.

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