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.

Mongolia is strengthening its beneficial ownership processes, laws, and systems. In fact, a comprehensive beneficial ownership disclosure regime requires careful consideration of challenges beyond the public register.

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.


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

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