On 23 November, an Occasional Paper from RUSI says that beneficial ownership information should be used to support greater financial system integrity, and the Paper explores its applications and what they mean for policymaking.  The Paper proposes questions that governments should consider when mandating beneficial ownership disclosure (see the Annex to the Paper) and structure findings and recommendations in the following 5 principles that can help answer these questions –

  1. Domestic verification – to ensure that the beneficial ownership information is accurate, the burden of verifying the information must be placed on the state;
  2. External validation – confidence in a state’s beneficial disclosure system requires external validation;
  3. Proactive use – a proactive approach is necessary, including reviewing the data for anomalies and revisiting it in light of news stories and newly uncovered typologies;
  4. Parity – beneficial ownership information in respect of various types of entities is not always collected and disclosed consistently; and
  5. Accessibility – those with a right to access beneficial ownership information should be able to do so without significant financial or bureaucratic barriers; and governments should consider the needs of both domestic and foreign law enforcement agencies and tax authorities, as well as those of the regulated businesses and public at large.

I had omitted the following link (as it did not seem to generate much interest!), but it seemed time to add it again and say that, if you would like to make a (polite) gesture and help me with my removal and computer costs, I have a page at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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