Financial Transparency Coalition

An important announcement came through today at the Our Oceans Conference in Mombasa, Kenya, this week as sixteen nations have signed up to the Mombasa Declaration, which is a commitment to advance global fisheries transparency including a commitment to beneficial ownership transparency of all fishing vessels.  It builds on the Global Charter for Fisheries Transparency by the Coalition for Fisheries Transparency.

This is a major step towards efforts to end the secrecy of company ownership as one of the commitments in terms of vessels that are responsible for illegal, unreported, and unreported (IUU) fishing costing an estimated US$ 23.5 billion in illicit financial flows (IFFs) every year from coastal nations with our report ‘Fishy Networks‘ estimating that 49% of this taking place in Africa.

The sixteen signatory nations are: Belgium, Cameroon, Chile, Republic of Congo, the Dominican Republic, France (on behalf of its overseas territories), Gabon, The Gambia, Ghana, Guinea, Liberia, Panama, Papua New Guinea, Peru, Somalia and South Korea.

These signatory countries will begin the implementation phase of this Declaration, and more countries may still join the call through the 2027 Our Oceans Conference in Mombasa.

To implement the commitment on beneficial ownership transparency, it’s vital that each country first and foremost establishes a centralised beneficial ownership registry to record all beneficial owners in the entire country.  This is also what is required by the Financial Action Task Force (FATF) recommendation 24, requiring centralised registries of beneficial owners, what was agreed at the Compromise de Sevilla, the outcome document of the 4th International Conference on Financing for Development (FfD4) that sought to establish a ‘Global Beneficial Ownership Registry’ (paragraph 28).

Of the signatory nations most have already established centralised BO registries including Belgium (2018), Cameroon (2023), Chile (no registry, UBO definition exists, implemented only for public procurement), Republic of Congo (2024), The Dominican Republic (2017), France (2016), Gabon (no registry, a commitment only for extractive industries), The Gambia (no centralised beneficial ownership registry), Ghana (2017, a fully publicly accessible BO registry), Guinea (no registry, a commitment only for extractive industries), Liberia (2023), Panama (2020), Papua New Guinea (only for extractive industries), Peru (2018), Somalia (no registry) and South Korea (2025).

However, only four signatory countries have either made or pledged to make their registry publicly available, as stated as the highest level of ambition in the Mombasa Declaration, even if not yet required by the signatories.  Ghana has made its beneficial ownership registry publicly accessible, where anyone can find key data of a natural person owning a company, including full name, year and month of birth, place of birth, percentage of beneficial ownership interest, and if the person meets the criteria of a Politically Exposed Person (PEP).  Meanwhile, in Belgium you can make a case-by-case basis request to access the BO registry, which is incredibly slow as a method of access, while in France allows full full access to the BO registry for those who can prove a legitimate interest.  Meanwhile, Panama has pledged to create a publicly accessible registry of all beneficial owners of fishing vessels.

In addition to public access, the quality of information is also critical in beneficial ownership registries.  This includes a high level of verification of beneficial owners, rather than just declaring them voluntarily, mandating an ID check (including an electronic one) is becoming more common.  Standardised data, automated access are also important for searching connections between complex ownership chains. Also, while some countries are making their beneficial ownership registries accessible for free, other countries do charge for the legitimate interest access, making access more difficult.

We hope that more countries commit that have signed the Mombasa Declaration will be opening up their beneficial ownership registries to the public, and ensure also that these registries have high-quality and verified data, and allow for a user-friendly way to access it.

Read more about the Mombasa Declaration.