Beneficial Ownership Transparency in Mongolia: Tackling Complex Implementation Issues

Beneficial ownership refers to natural persons who directly or indirectly ultimately own and derive financial benefit from a company or commercial activity. Beneficial ownership disclosure allows the general public to understand who has control of a company or a stake on it, so potential conflicts of interest can be identified and prevented. With more mechanisms for monitoring from governments, and the increasing importance of beneficial ownership registries, there is a global trend towards disclosure of this type of information. However, challenges remain significant.

Project: Leveraging Transparency to Reduce Corruption in the Natural Resource Industries

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With an ecosystem approach to beneficial ownership, the Leveraging Transparency to Reduce Corruption (LTRC) project, a joint initiative of the Brookings Institution and Results for Development, is supporting actors in Mongolia identifying implementation gaps and viable solutions to concrete challenges .
Building upon the findings and recommendations for a public register in a first report, Beneficial Ownership in Mongolia: A Way Forward, this follow up study focuses on how to tackle complex implementation challenges, based on lessons from other countries and a discussion of Mongolia’s context. These implementation issues are:

• Reporting regulations for State-Owned Enterprises
• Disclosure requirements for companies listed on a stock exchange with varied shareholders
• Definition and identification of foreign Politically Exposed Persons
• Elements related to verification measures for a public register
• Clarifications on the definition of indirect control
• Benefits and challenges associated with a public register

The report concludes with concrete recommendations for government and parliamentarian officials in Mongolia championing its beneficial ownership process.

Authors

• Michael Barron
• Tim Law
• Batsugar Tsedendamba
• Ariuntsetseg Jigmeddor