UK Overseas Territories commit to implement Accessible Registers of Beneficial Ownership

The Joint Ministerial Council (JMC) of the UK Overseas Territories, meeting in London on 21 November, committed to completing plans to implement Accessible Registers of Beneficial Ownership, with some territories implementing registers with legitimate interest access and others implementing fully publicly accessible registers.

Ahead of the meeting, a group of 40 MPs had signed a letter to UK Foreign Secretary David Lammy urging him to press for rapid progress on beneficial ownership registries at the annual summit. The letter highlighted a previous pledge by Overseas Territories and Crown Dependencies to implement full public beneficial ownership registers by the end of last year.

Disclosure of the data was mutually agreed following a 2018 UK parliament vote that called for the records to be made public. The parliamentarians argued in the letter that publishing the registers would enable journalists and investigators to follow money held offshore to uncover economic crime, rather than relying on leaks such as the Panama Papers.

Montserrat and Gibraltar have already implemented Publicly Accessible Registers of Beneficial Ownership (PARBOs) and the Falkland Islands and Saint Helena are due to follow suit by April 2025. Other UK Overseas Territories have agreed to implement legitimate access registers, which grant access to journalists and non-governmental organisations — a move the UK government regards as an interim step towards a fully public register.

In a communiqué issued at the conclusion of the summit, the governments of the Overseas Territories said they welcomed the launch of the Foreign Secretary’s campaign to prevent the use of the international financial system for illicit finance and kleptocracy, and committed to improving corporate transparency by completing plans to implement Accessible Registers of Beneficial Ownership, with some Territories implementing registers with legitimate interest access and others implementing fully publicly accessible registers.

“We note the UK government’s ambition that PARBOs become a global norm and its expectation that Overseas Territories and Crown Dependencies implement full PARBOs,” said the communiqué.

“We note commitments by Anguilla, Bermuda, the British Virgin Islands, the Cayman Islands and the Turks & Caicos Islands to implement Legitimate Interest Access Registers of Beneficial Ownership with the maximum possible degree of access and transparency, whilst containing the necessary safeguards to protect the right to privacy in line with respective constitutions.

“Where not already in place, Anguilla, Bermuda, the British Virgin Islands, the Cayman Islands and the Turks & Caicos Islands will have legislation on registers of beneficial ownership approved through their respective legislatures by April 2025, with implementation by June 2025 or earlier.”

The communiqué further noted that the UK and the Overseas Territories confirmed their commitment to effective implementation and robust enforcement of UK sanctions, to urgently building additional sanctions enforcement capability and addressing the sanctions vulnerabilities across the Overseas Territories, and to improving sanctions cooperation between the UK and the Overseas Territories.

“We recognise the concerted efforts to implement the Russia and other sanctions regimes by the Overseas Territories. The Cayman Islands’ ‘Operation Hektor’ approach is an example of an effective OT initiative. The Overseas Territories have frozen accounts and assets worth over GBP7 billion,” it said.