Beneficial Ownership Data Standard

Beneficial ownership data is difficult because ownership and control can be direct, indirect, layered, contractual, nominee-based or hidden through legal arrangements. A standard data model helps describe ownership information consistently.

1. What BODS is #

The Beneficial Ownership Data Standard (BODS), developed by Open Ownership with Open Data Services, is an open standard for collecting, sharing and using beneficial ownership data.

It is not a sanctions list and not a risk database. It is a structured way to represent ownership and control information.

2. Relevance to AML Bible #

In AML Bible, BODS concepts can be used to make UBO materials clearer:

  • person statements;
  • entity statements;
  • ownership or control statements;
  • interests;
  • start and end dates;
  • source and confidence metadata;
  • missing or unknown information.

3. AML use #

AML question BODS-style benefit
Who owns the entity? Separates entity, person and relationship data
How is control exercised? Records type of interest or control
When did ownership apply? Supports time-bound evidence
Is the data reliable? Source and confidence metadata can be recorded
Is anything missing? Unknown or unavailable information can be made explicit

4. Evidence cautions #

A clean ownership chart does not prove that there is no hidden control. BO data must be assessed against documents, registries, customer declarations, adverse media, nominee indicators and transaction behaviour.

5. Source basis #

  • SRC-OO-001: Open Ownership Beneficial Ownership Data Standard.
  • SRC-FATF-004: FATF beneficial ownership guidance for legal persons.
  • SRC-FATF-005: FATF beneficial ownership guidance for legal arrangements.

Data-model and investigative layers#

The Open Ownership data standard structures beneficial-ownership data. StAR's nominee-arrangements research (SRC-STAR-NOMINEES-001) explains why structured fields alone may not reveal effective control.

A robust analysis process therefore separates:

  • data representation;
  • source provenance;
  • legal ownership;
  • effective control;
  • nominee or intermediary role;
  • unresolved discrepancy and reviewer inference.