On 25 October, FATF advised that, at the March 2022 Plenary, FATF adopted amendments to Recommendation 24, and agreed to immediately start the work to update guidance on beneficial ownership, with a view to help support the implementation of the new requirements.  FATF now welcomes comments to its updated Guidance paper to Recommendation 24 on the transparency and beneficial ownership of legal persons. The draft text of the Guidance is available online.  It seeks views from companies and other legal persons, financial institutions, designated non-financial businesses and professions (DNFBP), and non-profit organisations (NPO).  However, contributions from other interested stakeholders are also solicited. In particular, comments are welcome on the following specific issues:

  1. Whether the Guidance is clear or are there any issues which need further clarification.
  2. Are there case examples of registries and alternative mechanisms for holding of accurate, adequate and up-to-date beneficial ownership information?
  3. Are there case examples of mechanisms to verify beneficial ownership information in low-risk scenarios?
  4. Are there case examples of the use of information held by stock exchanges for listed companies to meet beneficial ownership information obligations?



Any modest contributions for my time and ongoing expenses are welcomed! 

At Buy me a Coffee single contributions start as low as $3, 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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