Beneficial Ownership in Mongolia: A Way Forward

Beneficial ownership transparency (BOT) is important to build trust and confidence in the integrity of extractive industries, and indeed a country’s entire economy. Demands from international investors, finance providers, and citizens for increased transparency around the ultimate ownership and benefit derivation from extractive activities are growing. Meanwhile, more and more governments worldwide seek to clamp down on tax evasion, corruption and money laundering.

Mongolia, as it continues to compete with other countries to attract investment and financing to its mining sector, will need to meet the expectations of greater transparency in its extractives sector. It has already introduced the concept of BO into its legislation as part of anti-money laundering laws. However, implementation is lacking, with many parts of the BOT process incomplete.
The Leveraging Transparency to Reduce Corruption (LTRC) project, a global action-research initiative led by the Brookings Institution’s Governance Studies Program and Results for Development’s Accountability and Citizen Engagement practice, seeks to identify and build the conditions for an effective beneficial ownership ecosystem in Mongolia. In a November 2020 roundtable with stakeholders in Mongolia from civil society, government, and international organizations, several research priorities emerged, including the need to review the legislative framework that governs BOT and the supply of data in the registry.

This report, the first in the larger research agenda that was defined, analyzes the pending beneficial ownership (BO) agenda and a recommended path to implementation in Mongolia’s mining sector. It outlines clear recommendations on actions that government, parliamentarians, civil society, and business stakeholders in Mongolia can take to enhance the collection, storage, verification, and public disclosure of BO information. It is based on a structured and rigorous review of Mongolia’s BO legislation and mechanisms, as well as in-depth interviews with Mongolian government officials, civil society representatives, and international stakeholders.

The report comprises the following sections:

  • Assessment of the current BO situation in Mongolia and the register of government assets
  • Description of the international architecture of BO
  • Stakeholder mapping and engagement
  • Gap analysis of the current situation in Mongolia vis-à-vis international best practice
  • Recommendations and next steps


  • Michael Barron, Michael Barron Consulting
  • Tim Law, Engaged Consulting
  • Jake Hartnett, Consultant
  • Batsugar Tsedendamba, Independent Researcher
  • Amar Adiya, Managing Editor of and Director at BowerGroupAsia
  • Ariuntsetseg Jigmeddorj, Research Assistant

This Project was funded by the BHP Foundation.


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