BIOG - Basel AML Index 2021 10th Edition

Basel AML Index 2021: 10th Public Edition Ranking money laundering and terrorist financing risks around the world

- BASEL INSTITUTE ON

P GOVERNANCEBASEL AML INDEX 10TH PUBLIC EDITION 2021

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1 INTRODUCTIO N

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2 TREND 1: VIRTUAL ASSETS AND MONEY LAUNDERING

11 3 TREND 2: EFFECTIVENESS OF AML / CFT SYSTEMS 15 4 TREND 3: BENEFICIAL OWNERSHIP AS A PILLAR OF EFFECTIVE AML / CFT SYSTEMS 21 5 TREND 4: ML / TF VULNERABILITIES BEYOND THE FINANCIAL SECTOR 24

6 SCORES AND RANKING

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7 REGIONAL FOCUS

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8 EXPERT EDITION AND EXPERT EDITION PLUS

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9 ABOUT AND CONTACT

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10 ANNEX I: METHODOLOGY 50 11 ANNEX II: JURISDICTIONS NOT INCLUDED DUE TO A LACK OF 4TH-ROUND

FATF EVALUATION3

BASEL AML INDEX 10TH PUBLIC EDITION 2021

Acronyms and abbreviations AML Anti-Money Laundering AMLD Anti-Money Laundering Directive (EU) CDD Customer Due Diligence CFT Counter Financing of Terrorism DNFBP Designated Non-Financial Businesses and Professionals EU European Union FATF Financial Action Task Force IO Immediate Outcome (FATF effectiveness measure) ML / TF Money Laundering and Terrorist Financing

R. Recommendation (FATF standard)

TCSP Trust and Company Service Provider UAE United Arab Emirates US United States VASP Virtual Asset Service Provider WEF World Economic Forum About this report The Basel AML Index is developed and maintained by the International Centre for Asset Recovery at the Basel Institute on Governance. This report is licensed under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License

(CC BY-NC-ND 4.0).

WEF World Economic Forum About this report The Basel AML Index is developed and maintained by the International Centre for Asset Recovery at the Basel Institute on Governance. This report is licensed under a Creative Commons Attribution-NonCommercial-NoDerivatives 4.0 International License

(CC BY-NC-ND 4.0).

Suggested citation: Basel Institute on Governance, 2021. Basel AML Index 2021: 10th Public Edition – Ranking money laundering and terrorist financing risks around the world . Available at: https://index.baselgovernance.org .

While we have made reasonable efforts to ensure the accuracy and completeness of information provided in this report, neither the authors nor the Basel Institute on Governance nor our donors and collaborators assume any responsibility or liability for any errors or omissions, or for your use of the information and opinions contained in the report. Please send any feedback to: index@baselgovernance.org.4 BASEL AML INDEX 10TH PUBLIC EDITION 2021 1 Introduction This report accompanies the 10th Public Edition of the Basel AML Index, released in September 2021. The Basel AML Index measures the risk of money laundering and terrorist financing (ML / TF) in jurisdictions around the world. Risk, as measured by the Basel AML Index, is defined as a jurisdiction’s vulnerability to ML / TF and its capacities to counter it; it is not intended as a measure of the actual amount of ML / TF activity in a given jurisdiction. Published annually since 2012, the Basel AML Index remains the only independent, research-based index by a non-profit organisation ranking jurisdictions according to their risk of ML / TF. 1.1 Calculating and interpreting risk scores Risk scores are based on data from publicly available sources such as the Financial Action Task Force (FATF), Transparency International, the World Bank and the World Economic Forum. They cover 17

indicators in five domains relevant to assessing ML / TF risk at the jurisdiction level:

1. Quality of AML / CFT Framework

2. Bribery and Corruption

3. Financial Transparency and Standards

4. Public Transparency and Accountability

5. Legal and Political Risks The Public Edition of the Basel AML Index reflects the overall score of jurisdictions in terms of their risk exposure to ML / TF. However, and while the Basel AML Index does provide a ranking in accordance with this score, we strongly advise against a superficial comparison of countries in accordance with their ranking.

Instead, we encourage users to look at regional and global trends, and developments over time, and at what the Basel AML Index says about remaining weaknesses in the global response to ML / TF. We also encourage users to conduct a more in-depth analysis of individual countries or regions or risk factors by using the more comprehensive data that is available in the Expert Edition .5

BASEL AML INDEX 10TH PUBLIC EDITION 2021 1 INTRODUCTION 1.2 AML risk trends in 2021

Crunching data on money laundering risks for the Basel AML Index reveals interesting – and often concerning – trends. This year, we look at the data behind four topics that are hitting headlines: Virtual assets The latest data on how jurisdictions are responding to money laundering threats related to virtual assets.

The answer: not well at all.

Effective AML systems Are jurisdictions more effective at prevention of money laundering or at enforcement? Ineffective systems are the general rule, but jurisdictions consistently score worse for prevention than for enforcement. Beneficial ownership How slow and ineffective implementation of beneficial ownership registries continues to provide safe havens for dirty money. This is damaging for individual jurisdictions, but more importantly undermines all global efforts to combat money laundering. Non-financial professions Lawyers, accountants, real estate agents and other non-financial businesses and professions continue to underperform on compliance with AML / CFT standards. More supervision is urgently needed to close that gap. These concerns are described in the following sections, followed by an analysis of regional risk trends

Non-financial professions Lawyers, accountants, real estate agents and other non-financial businesses and professions continue to underperform on compliance with AML / CFT standards. More supervision is urgently needed to close that gap. These concerns are described in the following sections, followed by an analysis of regional risk trends and insights. 1.3 Methodology and expert review The methodology is described in detail in Annex I, with more information on the underlying indicators available on our website. It is essential to familiarise yourself well with the methodology to ensure that you fully understand what the Basel AML Index can and cannot show. This will ensure that you interpret the results properly and that any action you may take in response to the ranking is well founded. The method employed by the Basel AML Index to calculate the risk scores is reviewed every year by an independent panel of experts to ensure that the method continues to meet best practice standards, and that the ranking is accurate, plausible and continues to capture the latest developments in ML / TF risks. View the Basel AML Index interactive map and ranking on our new website at index.baselgovernance.org6 BASEL AML INDEX 10TH PUBLIC EDITION 2021 1 INTRODUCTION 1.4 Public, Expert and Expert Plus editions Public Edition The Public Edition of the Basel AML Index 2021, and the analysis in this report, covers 110 jurisdictions . This year, we are including only jurisdictions that have been evaluated using the FATF’s fourth-round methodology, in order to provide a reliable basis for comparison. A separate list in Annex II also includes 45 jurisdictions with older FATF evaluations but otherwise sufficient data to calculate a risk score.

Expert Edition The Expert Edition, which includes a customisable interactive ranking, jurisdiction profiles and data downloads, covers 203 jurisdictions. Companies and financial institutions use the Expert Edition for compliance and risk assessment purposes. In the public sector and academia, the Expert Edition supports AML / CFT research and policymaking.

Expert Edition Plus Expert Edition Plus subscribers benefit from an in-depth quantitative and written analysis of FATF reports, plus special

203 jurisdictions. Companies and financial institutions use the Expert Edition for compliance and risk assessment purposes. In the public sector and academia, the Expert Edition supports AML / CFT research and policymaking.

Expert Edition Plus Expert Edition Plus subscribers benefit from an in-depth quantitative and written analysis of FATF reports, plus special reports on money laundering risks in Jersey, Guernsey, Isle of Man, Gibraltar and the Cayman Islands.7 BASEL AML INDEX 10TH PUBLIC EDITION 2021 2 Trend 1: Virtual assets and money laundering The latest data on how jurisdictions are responding to money laundering threats related to virtual assets. The answer: not well at all. 2.1 Money laundering threats from cryptocurrencies The use of virtual assets such as cryptocurrencies is exploding – for legitimate as well as illicit purposes. In January 2021, there were an estimated 106 million cryptocurrency users globally. Data on how any of these may be using cryptocurrencies for criminal purposes, including to launder stolen money, is however scarce. According to a 2021 report by blockchain analysis firm Chainalysis , of the estimated USD 21.4 billion in cryptocurrency transactions in 2019, criminal activity represented around 2.1 percent (USD 450 million). Cryptocurrencies have unique characteristics, many of which are very positive, including for example the potential to improve financial inclusion. Yet their borderless nature and existence outside the formal financial system also make them a tempting option for criminals to conceal proceeds of corruption and other crimes, evade tax or fund terrorism. Box 1: Mitigating ML / TF threats from virtual assets – FATF Recommendation 15 In 2018, in an effort to motivate jurisdictions to take action to prevent virtual assets becoming a threat to global financial stability, the FATF revised its Recommendation 15 on virtual assets and virtual asset service providers (VASPs). Finalised amendments, an Interpretive Note and accompanying Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers followed in 2019. In essence, the revised Recommendation requires among other things: • Jurisdiction must apply a risk-based approach to AML / CFT risks associated with virtual assets.

Interpretive Note and accompanying Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers followed in 2019. In essence, the revised Recommendation requires among other things: • Jurisdiction must apply a risk-based approach to AML / CFT risks associated with virtual assets. • VASPs should be licensed/registered, and subject to adequate regulation and supervision. • VASPS must conduct customer due diligence on one-off transactions over USD/ EUR 1,000, and submit suspicious activity reports where needed.8 BASEL AML INDEX 10TH PUBLIC EDITION 2021 2 TREND 1: VIRTUAL ASSETS AND MONEY LAUNDERING • VASPs should obtain information about the originator and beneficiary of transfers and make it available to competent authorities (the so-called travel rule). The FATF defines the term “virtual asset” as any “digital representation of value that can be digitally traded, or transferred, and can be used for payment or investment purposes”. This does not include digital representations of fiat currencies or other financial assets included elsewhere in its Recommendations. VASPs include natural or legal persons that offer services such as exchanging between virtual assets and fiat currencies, exchanging between different forms of virtual assets, transferring virtual assets, safekeeping or administering virtual assets, or providing other financial services relating to virtual assets. In July 2020 and July 2021, the FATF issued the first and second reports on the results of 12-month reviews on the revised standard. 2.2 How are jurisdictions doing at mitigating their risks of money laundering using virtual assets? It is still early days, as the final version of the revised Recommendation 15 was only issued in June

2019. However, initial signs are not encouraging. • Of the 27 jurisdictions assessed or reassessed 1 for technical compliance with the new R.15 from June 2020 to June 2021, 19 downgraded their scores . Five jurisdictions retained the same scores and only three managed to improve. • The average compliance score for R.15 across all jurisdictions assessed with the latest (fourthfrom June 2020 to June 2021, 19 downgraded their scores . Five jurisdictions retained the same scores and only three managed to improve. • The average compliance score for R.15 across all jurisdictions assessed with the latest (fourthround) FATF methodology decreased from 70% to 60%. • Of the 10 jurisdictions assessed with Mutual Evaluation Reports, none was rated as being compliant. Two jurisdictions were non-compliant (score of 0), 5 were partially compliant (score of 1 out of 3) and 3 were largely compliant (score of 2 out of 3). 19 decreased 5 stayed the same 3 increased 70% 19% 11% 1 Ten jurisdictions were assessed with Mutual Evaluation Reports. Seventeen jurisdictions were re-assessed with Follow-Up Reports. All reports are available on the FATF website .9

BASEL AML INDEX 10TH PUBLIC EDITION 2021 2 TREND 1: VIRTUAL ASSETS AND MONEY LAUNDERING 2.3 Is there a risk of “regulator shopping” in the virtual assets sector? Yes. The consequences of individual failings by jurisdictions in implementing effective AML / CFT requirements on VASPs could be serious. The reason is simple and visible in regular money laundering schemes too: criminals wishing to abuse virtual assets for illicit purposes can simply switch from jurisdictions with a strong regulatory framework to one in which regulations are weak and not enforced. This risk is exacerbated by the hyper-global nature of virtual assets. A lack of coordinated and concerted global action may therefore result in some jurisdictions becoming safe havens for illicit activity using virtual assets. This challenge has been recognised by the European Commission’s June 2021 package of proposals to tackle ML / TF, which includes an ambitious plan to harmonise AML / CFT legislation, in relation to VASPs, across all EU jurisdictions. This is a positive move, but without similar efforts among other jurisdictions and regional bodies, it is likely that the illicit activity will simply move to locations with fewer or no controls. 2.4 What are the biggest issues to fix, and how can jurisdictions with upcoming FATF assessments obtain a better evaluation?

jurisdictions and regional bodies, it is likely that the illicit activity will simply move to locations with fewer or no controls. 2.4 What are the biggest issues to fix, and how can jurisdictions with upcoming FATF assessments obtain a better evaluation? The FATF’s second review of trends with regard to the implementation of the revised R.15 indicated progress in certain areas, including with respect to transposing the new requirements into domestic legislation, submitting suspicious activity reports and establishing supervisory regimes. Significant gaps however remain, in particular in the following areas: • Weak implementation of the “travel rule” (see Box 1), meaning that information on the originators and beneficiaries of cryptocurrency transactions is not being obtained or made available to competent authorities. • Sluggish action by jurisdictions in implementing AML / CFT obligations in the virtual assets sector, with infrequent examinations or sanctioning. • Generally, a lack of knowledge and expertise among supervisory/regulatory bodies in the field of virtual assets, reducing their ability to oversee and guide VASPs.10 BASEL AML INDEX 10TH PUBLIC EDITION 2021 2 TREND 1: VIRTUAL ASSETS AND MONEY LAUNDERING 2.5 What data is available to assess ML / TF risks relating to virtual assets? The new and fast-evolving nature of the virtual assets sector means that reliable data relevant to evaluating money laundering risks is not widely available. Regular market data on virtual assets, such as the use of cryptocurrencies and the location of cryptocurrency mining centres, are largely collected and analysed by blockchain analytic companies such as Chainalysis, CipherTrace, Coinfirm, Elliptic, Merkle Science, Scorechain, TRM Labs. 2 However, the differences in methodologies, analytical techniques and tools, along with the proprietary nature of the data, mean that comparability is difficult. The data also tend to focus on a select few cryptocurrencies only and are therefore not sufficiently comprehensive for this purpose. A prerequisite for evaluating risks of ML / TF relating to virtual assets is understanding geographical trends in their use and regulation. • Chainalysis issued a helpful analysis of such geographic trends in September 2020, although

cryptocurrencies only and are therefore not sufficiently comprehensive for this purpose. A prerequisite for evaluating risks of ML / TF relating to virtual assets is understanding geographical trends in their use and regulation. • Chainalysis issued a helpful analysis of such geographic trends in September 2020, although it does not provide data on the risk of misuse of cryptocurrencies. • Statistica published a list of jurisdictions with the highest cryptocurrency use per capita in March

2021. There is however no evidence as yet that a lack of regulation or intensive usage of virtual currencies in a population correlates with an increased risk of ML / TF using virtual assets.

We therefore suggest that the FATF assessment of jurisdictions’ compliance with R.15 remains the most reliable source of data on ML / TF risks relating to virtual assets. It also has the virtue of enabling comparisons across jurisdictions and measurement of progress over time. 2 These companies were selected by the FATF to develop market metrics on virtual assets.11 BASEL AML INDEX 10TH PUBLIC EDITION 2021 3 Trend 2: Effectiveness of AML / CFT systems Are jurisdictions more effective at prevention of money laundering or at enforcement? Ineffective systems are the general rule, but jurisdictions consistently score worse for prevention than for enforcement. 3.1 Assessing the effectiveness of AML / CFT systems Last year’s Basel AML Index lamented jurisdictions’ consistently poor results in terms of the effectiveness of their AML / CFT systems. It is all too common for jurisdictions to have laws and institutions in place that are largely compliant with FATF Recommendations yet ineffective in practice. The Wolfsberg Group, a Collective Action initiative of 13 global banks that develops frameworks and guidance on financial crime risks, reinforced our concerns in a June 2021 statement on Demonstrating Effectiveness: “[L]argely in response to supervisory expectations, AML / CFT risk assessments are focused on technical compliance with requirements rather than the effectiveness of the [financial institution’s] efforts to prevent and detect financial crime”. Data on the effectiveness of AML / CFT systems is drawn from the FATF Mutual Evaluation Reports.

“[L]argely in response to supervisory expectations, AML / CFT risk assessments are focused on technical compliance with requirements rather than the effectiveness of the [financial institution’s] efforts to prevent and detect financial crime”. Data on the effectiveness of AML / CFT systems is drawn from the FATF Mutual Evaluation Reports. The FATF’s fourth-round methodology uses 11 “Immediate Outcomes” (IOs) to assess the effectiveness of AML / CFT systems according to its 40 Recommendations. The 11 IOs and the assessment methodology are detailed on the FATF website . 3.2 Is there any sign of improvement in the figures for 2021? Not really. Based on the latest FATF data, the average score for effectiveness across all assessed jurisdictions is only 30%. That is two times lower than the average score for technical compliance with FATF Recommendations, which stands at 64%. Technical compliance 64% Effectiveness 30%12 BASEL AML INDEX 10TH PUBLIC EDITION 2021 3 TREND 2: EFFECTIVENESS OF AML / CFT SYSTEMS Weak spots vary between jurisdictions, but overall they are as follows: Money laundering offences and activities are investigated and offenders are prosecuted and subject to effective, proportionate and dissuasive sanctions. Legal persons and arrangements are prevented from misuse for money laundering or terrorist financing, and information on their beneficial ownership is available to competent authorities without impediments. Supervisors appropriately supervise, monitor and regulate financial institutions, DNFBPs and VASPs for compliance with AML/CFT requirements commensurate with their risks. Financial institutions, DNFBPs and VASPs adequately apply AML/CFT preventive measures commensurate with their risks, and report

compliance with AML/CFT requirements commensurate with their risks. Financial institutions, DNFBPs and VASPs adequately apply AML/CFT preventive measures commensurate with their risks, and report suspicious transactions. Persons and entities involved in the proliferation of weapons of mass destruction are prevented from raising, moving and using funds, consistent with the relevant UNSCRs. 21%22%26% 24% 25% Average effectiveness across all assessed jurisdictions IO11 WHAT IT MEASURES IO4IO3 IO5 IO7 3.3 Are jurisdictions doing better at prevention or enforcement? Ideally, AML / CFT systems need to be particularly effective at preventing money laundering from occurring. Enforcement remains of course important, and it must be effective. But relying too heavily on catching the criminals post factum presents an unreasonable risk and also means that some damage invariably will remain. So we should be asking if jurisdictions doing enough on the prevention side, or if they are too heavily focused on enforcement. To explore this question, we divided FATF data on effectiveness criteria (IOs, see chart above) into two categories: 3 3 IO2 is not included as it refers to elements of both prevention and enforcement, while IO11 is not relevant to the topic.13 BASEL AML INDEX 10TH PUBLIC EDITION 2021 3 TREND 2: EFFECTIVENESS OF AML / CFT SYSTEMS Prevention Enforcement IO1: Risk, policy and coordination IO7: Money laundering investigation and prosecution IO3: Supervision IO8: Confiscation IO4: Preventive measures IO9: Terrorist financing investigation and prosecution IO5: Legal persons and arrangements IO6: Financial intelligence (mainly enforcement) IO10: Terrorist financing preventive measures (mainly prevention)

Based on an analysis of 112 jurisdictions assessed with the fourth-round methodology by 15 July 2021,

prosecution IO5: Legal persons and arrangements IO6: Financial intelligence (mainly enforcement) IO10: Terrorist financing preventive measures (mainly prevention)

Based on an analysis of 112 jurisdictions assessed with the fourth-round methodology by 15 July 2021, the data shows that jurisdictions are less effective at preventing ML / TF than at enforcing AML / CFT measures. And this is in a context where performance for enforcement is unsatisfactory already. • Globally, average effectiveness for prevention was 27%, compared to 31% for enforcement. • Nineteen jurisdictions (17%) scored zero for the effectiveness of their preventive measures, compared to 12 jurisdictions (11%) for enforcement. • Nine jurisdictions demonstrated zero effectiveness in both prevention and enforcement criteria. These are: Cape Verde, Democratic Republic of the Congo, Haiti, Mali, Mauritania, Mozambique, Pakistan, Uganda and Vanuatu. • The UK and Spain are the only jurisdictions assessed so far to achieve scores of 67% or above for both prevention and effectiveness criteria. A regional perspective shows some variation, but the same overall story: When it comes to money laundering, jurisdictions seem to be more effective at enforcement than prevention. That being said, it is a well known fact that measuring effectiveness in prevention is considerably more difficult than measuring effectiveness at enforcement, for which data and statistics are often available from law enforcement and judicial actions.14 BASEL AML INDEX 10TH PUBLIC EDITION 2021 3 TREND 2: EFFECTIVENESS OF AML / CFT SYSTEMS Region Prevention average Enforcement average East Asia and Pacific 26% 32% Eastern Europe and Central Asia 37% 38% Latin America and Caribbean 25% 26%

Middle East and Northern Africa 32% 40% North America 53% 56% South Asia 7% 13% Sub-Saharan Africa 5% 8% Western Europe and EU 37% 43% These findings should ring an alarm bell for policy makers. Jurisdictions should invest more resources in the prevention of ML / TF, because a fire contained is always better than an arsonist caught when the house has burnt down, while of course the arsonists must be caught and punished. That being said, we are far from arguing that such an increase of resources for prevention should come at the detriment of enforcement. On the contrary, both sides clearly need a serious boost, except perhaps the boost for prevention needs to be even more serious than that for enforcement.15 BASEL AML INDEX 10TH PUBLIC EDITION 2021 4 Trend 3: Beneficial ownership as a pillar of effective AML / CFT systems How slow and ineffective implementation of beneficial ownership registries continues to provide safe havens for dirty money. This is damaging for individual jurisdictions, but more importantly undermines all global efforts to combat money laundering. 4.1 Beneficial ownership and resilience to ML / TF threats Beneficial ownership transparency is directly related to the effectiveness of a jurisdiction’s AML systems and the essential role of these systems in preventing, detecting, prosecuting and sanctioning financial crimes. It is therefore crucial to a jurisdiction’s resilience against ML / TF threats. Both public authorities (law enforcement, Financial Intelligence Units) and private actors (financial institutions and Designated Non-Financial Businesses and Professions, or DNFBPs) are responsible for maintaining this resilience. For public authorities , low transparency of beneficial ownership and anonymity of some legal arrangements hamper ML / TF investigations and attempts to trace and freeze illicit assets. This is because of the very nature of money laundering, which is to disguise the criminal origins of money and take a number of actions to introduce it into the financial system and make it appear legal. Criminals often use complex “layers” of legal corporate structures spanning multiple jurisdictions to

This is because of the very nature of money laundering, which is to disguise the criminal origins of money and take a number of actions to introduce it into the financial system and make it appear legal. Criminals often use complex “layers” of legal corporate structures spanning multiple jurisdictions to hide the illicit origin of their money. If such layering activities remain undetected, the money is more easily integrated into the financial system. It then becomes much more difficult for law enforcement authorities to identify and prosecute the crimes and to recover whatever is left of the money. This is especially the case where the trail of the money passes through multiple jurisdictions with very different methods for recording and sharing beneficial ownership information. This problem of opaque beneficial ownership arrangements also applies to terrorist financing crimes, where criminals aim not only to stay undetected but to circumvent sanctions lists. For the private sector, the information contained in beneficial ownership registers is also essential to effective AML / CFT compliance processes.16

BASEL AML INDEX 10TH PUBLIC EDITION 2021 4 TREND 3: BENEFICIAL OWNERSHIP AS A PILLAR OF EFFECTIVE...

Financial institutions and DNFBPs effectively play a gate-keeping role to prevent illicit money from entering the financial system. Without proper access to reliable information on beneficial ownership, private actors have a limited ability to understand who is behind the legal entities and legal arrangements – i.e. a limited ability to fulfil their customer due diligence requirements. They are therefore not able to perform their role of preventing financial crimes and of protecting their own businesses to their full capacity. The financial institutions and DNFBPs themselves also suffer as a result of a jurisdiction’s dysfunctional or nonexistent beneficial ownership transparency: poor AML compliance increases their exposure to legal, reputational and financial (fines) risks. 4.2 Beneficial ownership transparency has risen up the global agenda The FATF published the first international standards on beneficial ownership transparency in 2003. 190 jurisdictions committed to implementing legal requirements for: • financial institutions and other gatekeepers to collect and verify information on the ownership of legal persons and arrangements; • measures to ensure that this information is available competent authorities.

The FATF published the first international standards on beneficial ownership transparency in 2003. 190 jurisdictions committed to implementing legal requirements for: • financial institutions and other gatekeepers to collect and verify information on the ownership of legal persons and arrangements; • measures to ensure that this information is available competent authorities. The standards were revised in 2014 to provide more clarity, close loopholes and better distinguish between basic ownership information (about the immediate legal owners of a company or trust) and beneficial ownership information (about the persons who ultimately own or control it). In 2019, FATF published best practices on beneficial ownership for legal persons. There is now widespread consensus that beneficial ownership registers are needed not only to combat ML / TF but also tax evasion and other forms of financial crime, to assist in tracing and recovering stolen assets, and – especially for publicly available registers – for their deterrent ef