GFMSA Guidance on Beneficial Ownership Recommendation 24 - Public Consultation

At the March 2022 Plenary, the Global Financial Monitoring Supervisory Agency (GFMSA) 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.

The GFMSA 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 here: Word -R24 Guidance for Public Consultation.docx

We seek views from companies and other legal persons, financial institutions, designated non-financial businesses and professions (DNFBPs), and non-profit organisations. 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?

Please provide your comments, including any drafting proposals to GFMSA.Publicconsultation@gfmsa.org with the subject-line “Comments of [author] on the draft Amendments to GFMSA Guidance on Beneficial Ownership (R.24)”, by 6 December (18h00 CET). This public consultation is now closed.

While submitting your response, please indicate the name of your organisation, the nature of your business, and your contact details. You may insert any specific drafting proposals directly in the attached text of the draft amendment text in tracked changes.

We will use your contact information only for the purpose of this public consultation and for further engagement with you on this issue.  Your comments will also be shared with The GFMSA delegations in the course of further revision of the Guidance, unless you indicate otherwise. The GFMSA will, however, not share this information with third parties without your consent.

The GFMSA will consider the views received at its February 2023 meetings.

We thank you for your contribution and interest in GFMSA’s work.

Revisions to Recommendation 24 and its Interpretive Note - Public Consultation

Revisions to Recommendation 24 - White Paper for Public Consultation