The Global State of Beneficial Ownership Transparency

In this episode of Integrity Insights, host Filip Brokes speaks with Thom Townsend, Executive Director of Open Ownership, about the evolving global landscape of beneficial ownership transparency.

The conversation revisits one of the major turning points in the transparency agenda: the November 2022 Court of Justice of the European Union ruling, which restricted unrestricted public access to beneficial ownership registers. Thom explains how the decision created a “seismic shift” in Europe and beyond, prompting some jurisdictions to pause reforms or reassess public access models. At the same time, he highlights that the ruling also confirmed an important role for civil society, journalists and academia in fighting money laundering through access based on legitimate interest. 

The discussion also looks at the United States, where the rollback of the Corporate Transparency Act has added further uncertainty to the global reform agenda. Thom reflects on what this could mean for FATF standards, mutual evaluations and the incentives facing countries that are still considering or implementing beneficial ownership reforms.

A key theme of the episode is the difference between a register that merely exists and one that is genuinely useful. Thom explains why usability depends not only on whether data is accessible, but also on whether users can search by company and individual names, identify links across entities, access structured data, and rely on systems that support verification and cross-checking. He discusses examples from jurisdictions including Nigeria, Botswana, Austria, Denmark, Norway, South Africa and Argentina, showing that there is no single model for success.

The episode also explores the practical challenge of verification. Thom distinguishes between verifying the identity of a natural person and verifying whether that person genuinely owns or controls a company. He explains why verification is a “team sport” requiring discrepancy reporting, cross-government data sharing, tax-data checks, land and property registers, and credible deterrence mechanisms.

Despite political and legal headwinds, Thom remains broadly optimistic. He notes that around 150 to 160 jurisdictions have implemented, are implementing, or plan to implement beneficial ownership reforms, and argues that the global evidence base around beneficial ownership transparency is growing rapidly.

Documents referenced: 

1. The usable data framework - https://www.openownership.org/en/publications/usable-beneficial-ownership-data/ 

2. The Open Ownership map https://www.openownership.org/en/map/ charts progress globally.

3. Open Ownership's reaction to AML6 https://www.openownership.org/en/news/european-union-takes-important-steps-towards-standardised-and-interoperable-beneficial-ownership-information/

4. Open Ownership's response to the 2022 CJEU verdict https://www.openownership.org/en/news/statement-on-court-of-justice-of-the-european-union-cjeu-judgement-on-public-beneficial-ownership-registers-in-the-eu/

5. The launch of Open Ownership's new research project, BEAM https://www.openownership.org/en/blog/from-reform-to-results-introducing-beam-a-new-programme-to-measure-impact-in-beneficial-ownership-transparency/, which will work with researchers and academics to design more ways to measure the impact of BO information.

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Transcript

 Hello, everybody. Welcome to the latest episode of Integrity Insights. In this episode, I sat down with the executive director of the NGO Open Ownership, Tom Townsend, who is a really passionate fighter in the corporate transparency space. We talked about the state of beneficial ownership transparency around the world, not just in the EU and the United States, but in many other jurisdictions that don't get as much coverage. Tom has valuable insights into the subjects that are otherwise really hard to find elsewhere, so tune in if you want to learn more about the state of beneficial ownership transparency around the world. Hey, Tom, welcome on the podcast. Thank you for having me. It's a pleasure to be here. It's a pleasure to have you on. Uh, can you please, uh, give a quick intro, uh, to our listeners of yourself? My name is Tom Townsend. I'm the executive director of Open Ownership. We're an NGO that's about eight years old, and we work with governments around the world to help them design, deliver, and get the most out of beneficial ownership reforms. Uh, and the comp-- uh, the, the, the NGO was founded, I believe, in, uh, 2016. A little bit later than that. Um, we came about, um, as a result really of a big anti-corruption summit, um, that happened on the twelfth of May 2016, so, um, 10 years and one day ago when we're talking today. Um, that summit had a big focus on beneficial ownership. Um, and part of what was agreed there was that the UK government would support building architecture to support better beneficial ownership information globally. So that split out into two things. Number one, building a global register of beneficial ownership, um, when it was anticipated that most countries would start publishing data openly and freely. We now know 10 years later that that hasn't happened in the way that we, um, would have liked it to. So part of it was about building a global registry. The other part of it was about building a, a really good data standard. So figuring out how do we structure beneficial ownership information in data really, really effectively, such that it can be used and shared, um, among countries and, and used very effectively by journalists and civil society, business, and so forth. Um, so those were our sort of first two tasks and why Open Ownership was formed. Um, things have really changed over the last 10 years, though, in the space. Um, public access to information is no longer considered to be the sort of, uh, norm, I guess. Um, there's many more diverse ways of implementing this reform and giving access to information to people. Um, and I think also what we've really found as an organization is that most governments in the world really do need quite a lot of support over many years to get the legislation right, to be able to build, um, a system that really does make it easy for a business to disclose and a system that produces data that other departments, um, and others can use really, really effectively. So our work has really become quite focused on that, that hard long-term work of getting really good beneficial ownership reforms delivered. And I'm, I'm, I'm really glad that you, uh, agreed to join the podcast because we, we did, uh, actually our, our very first episode of Integrity Insights back in June 2023. I sat down with our managing partner, Jennifer Hen- Henley Girish, and we talked about the, uh, background of the BO- uh, beneficial ownership registries, the, the, the regulation in Europe and the, uh, European Court of Justice ruling from November 2022, which invalidated the fifth AML directive provision requiring unrestricted public access to beneficial ownership registers. And we saw, as a result, a lot of, uh, registries in European countries closing down or restricting access as a result. Um, maybe we could take it from here. Uh, how, how big of a blowback was, was this, uh, ruling for the, for the whole BO- beneficial ownership transparency agenda? It was a seismic shift. Overnight, the attitude towards the subject shifted. In European countries, of course, we saw the following day public access being shuttered. That was a direct response, of cour- of course, to the CJEU, um, and the, the mem- the countries that over which it has jurisdiction. What we saw globally was a number of jurisdictions kind of take a pause in their implementation or, or pause the public access element of it to try and understand how their data protection legislation, and in many countries that is inspired at least by the general data protection regulation in the EU, taking a moment to figure out what a public access regime might mean in their context and anticipating that they would see similar challenges in their courts to the one that, that took place in, in Europe. So there was that physical shuttering of public access in, in EU member states and as this kind of general pause it felt like around the world. You also saw from jurisdictions who were, we would generally call secrecy jurisdictions, um- A sort of sense that, okay, well, if the EU now has ruled or the CJEU has ruled that public access, um, is not legitimate, then, then we're not gonna have to change at all. We're delighted about this. We- we're not a European member state, but that is enough for us to be able to point to and tell the world, "Well, the EU's not doing it, so we're not doing it either." And those secrecy jurisdictions are some of them, of course, the British overseas territories in other countries as well. Uh, the court ruling remains the sort of, um, the one thing that opponents of, of transparency will point to, um, a- as the reason why they can't go further. I think there is a combination of things happening right now, though, that, that, um, are also very challenging. So we have the CGU judgment, of course, in 2022, but what we critically have now in the United States is a rollback of the Corporate Transparency Act. So you have 27 EU member states having a much more restricted approach to this. You have the world's largest economy having a much more restricted approach to this, ha- having passed legislation only a couple of years before and, and really only having a few months of implementation before the Corporate Transparency Act was, was kind of rolled back. So the picture today in 2026 is a much more contested place than it was 10 years ago. Um, there are many more ideas about how you do this well. There's much more pushback, and I don't feel confident predicting what the next four or five years will look like when it comes to issues of beneficial ownership transparency. I think there's countries that are doing amazing work and are going to be able to show us quite soon, I think, r- really good quantitative replical, uh, replicable evidence that this reform is worth doing. It's better for business. It tackles corruption, um, and improves governance. But yeah, there are serious headwinds, and I think if you layer on top of that the wider kind of economic changes that we're probably going to see as a result of new technology and the abilities and some of the challenges around things like fraud and spoofing and so on and so forth, um, yeah, I think the next five years are going to be, um, very interesting but also quite challenging from the perspective of getting this work done. Mm-hmm. I, I particularly like that you brought up this point of the United States. I actually wanted to ask this to you later on, but, uh, I would like to drill down a little bit more into this because as you said, if the other countries in, uh, in, you know, around the world, they are seeing what the Europeans are doing and then now the Americans are also putting this le- legislation on hold, like what, what kind of incentive, uh, then do th- those other countries, uh, have to, to, to promote this agenda? I think there are many, many different incentives that play in very different jurisdictions and I, I, I won't name specific, uh, jurisdictions necessarily, but will describe their features. I think in certain jurisdictions who are pushing very, very hard on this, it is a response to overwhelming political pressure to do something about grand corruption, to clean up public procurement, to ensure that public funds end up doing the public works projects that they want them to do. And the public is crying out for that. So the reforms sit front and center, um, in terms of delivering for an, for an angry public who's fed up of, of, of corruption. You've then, of course, got the impact of the Financial Action Task Force and its requirements around beneficial ownership reform and the threat of being gray-listed. Or indeed, if you are already gray-listed, how you, how you're going to get off it. I mean, doing beneficial ownership well is rarely the, the difference between, you know, being on or off the gray list, but it's an incredibly important component of it. So that's an incentive as well for, for reform. What is, I think, going to be quite fascinating is how the Financial Action Task Force assesses the United States right now. So their mutual evaluation is beginning shortly, I think. Um, it's not gonna report for a, for a, for a while, but the Financial Action Task Force is now going to have to report on one of its own members who has very, very publicly, uh, and very loudly announced that they are no longer going to be collecting information centrally from businesses registered in the United States as to who their beneficial owners are. So over to you, FATF, what do you think? Um, you have, you know, set a standard for the world and, and the world's largest economy, you may find, uh, is not meeting it. So that's gonna be an interesting moment to figure out what's going on. But I think around the world, um, the, the strongest incentive, I think, remains FATF compliance. But I think that domestic pressure to, um, ensure that corruption is tackled and, and governance is better is, is still there, and that is a driver for people to do the work. But I think it's not all bad. Um, I think one of the exciting things that has resulted from the European Court of Justice verdict in November 2022 is to instantiate the idea, and, and it's clear in the judgment that civil society and the media and academia have a role to play in fighting money laundering. And do you have a right to see the data? So yes, it restricts this sort of total public access from a privacy perspective, but it also says that those actors have a right to use this data. So whilst we have seen the kind of broad-based access, uh, res- be restricted, it's also been really helpful in making it very clear that, you know, these groups outside of government do have access to the data. And I think when you go and work in a jurisdiction where perhaps public access was never going to happen, this judgment has actually opened up a route by which more people can have access to more data I'm not trying to say that the European Court of Justice verdict is not something I would have liked to have seen go another way. I think public access is the, the most efficient and cheapest way of achieving the most public policy goals you have with beneficial ownership. But it's not all bad. Um, and it has, has opened up opportunities for countries to go further than perhaps they would before that European Court of Justice verdict. Okay. I really like your optimism there. And, uh, when we go back to the, the European Union, the European context, uh, at least last time I checked, uh, you know, there's in-- there's a massive d- discrepancy between how, uh, this-- the, the data is accessible from, uh, the, in the Czech Republic's, uh, Czech Republic is, uh, relatively easy to obtain this information from my experience. In some other countries, it's, it's, it's nearly impossible. And I just read that by July 2026, the European Commission is requiring EU member states to adopt a common set of standards that clarify what exactly counts as legitimate interest and kind of harmonize this, uh, uh, policy, uh, with regards to access to beneficial ownership information. Have you seen any progress, uh, on this? Because July is next month, and I haven't really seen much. Yeah, I, I think honestly, n- no. I mean, there are some countries that have put the system in place. You've just described one. Um, France would be another. Um, I haven't been through the long list of all member states and figured out exactly where they are at today. That's actually a very, um, time-consuming effort to go and seek legitimate interest access in all 27. Um, what should happen, of course, under the f- the sixth Anti-Money Laundering Directive is that your request for in, um, legitimate interest access in one member state should be portable into another. It should grant you access to, to the others, or at least not have to go through those processes. But I've, I've yet to see that work. It, it may well do. There may be people out there who are using a, um, a, an access or permission that they have got in one member state somewhere else, but I've, I've not seen it yet. Um, I also think from what we have seen that there are some challenges in feeling confident about how you can use the data. So the terms and conditions that are, are, are, uh, that pertain to your access, not always clear what acceptable usage is of that information. I think in broad terms there are. We as an organization, having got legitimate interest access, uh, in a couple of EU member states, um, did not feel that confident to use it In the ways that we'd want to, in fact, that we then needed quite, you know, costly legal advice to make sure we were on the correct side of all of that. I think that's normal for a new policy like this, this new policy area. Yes, by July, we're going to have to see something. We are gonna have to learn by doing a little bit. I think member states have got lots to do under the sixth Anti-Money Laundering Directive. Designing an effective legitimate interest taxat- access regime is not easy, as we are finding out. Um, and it's not necessarily quick to do either. So if I think about the totality of what member states are now being asked to do, and we in Europe are gonna have, you know, a powerful new, um, regulator in AMLA who is still setting things up, still writing rules, there is a lot to digest. So we're at this moment of sort of maximum effort and maximum rule making, and I think it's gonna take a couple of years for, for us to sort of really see what the impact of that is. But we are not going to find ourselves in July of twenty twenty-six enjoying some brave new world of legitimate interest access being completely fixed across EU member states, um, the data being provided in a kind of really nice structured interoperable way, which the, the sixth Anti-Money Laundering Directive requires in some form. And we're probably not going to see, you know, a new, um, version of BORIS, which was the Beneficial Ownership Registers Interchange System, i.e., a single access point where you can find any information from member states. It's just not going to happen quickly. Mm-hmm. And when we zoom out a little bit, not, so not necessarily in the European context, but overall with those, you know, globally with those, with those registries, what would you say separates a useful register from a, just a symbolic one? I think you have a, a, in your materials open ownership, you emphasize open and usable data. So what would you, how would you describe, uh, what usable actually mean in, in practice? We think about usable data, um, in, in a really broad way and is everything from what kind of search are you allowed to perform. Can you only search for a business? Or even better, can you search for a natural person and then see all of the businesses in which they have some degree of interest or beneficial ownership? Um, or do you need to know the company number because you can't search by name? Does the search only allow an exact match or will it return to you suggestions for fuzzy matching? All of those sorts of things, just at the point where you enter the platform for the first time, I think dictate how usable things are. If you're an investigative journalist and perhaps you are, as is the case with the new legitimate interest access regime in the British Virgin Islands- Looking to investigate a particular individual and their connections to companies that might be owned in that jurisdiction, um, you will have to make a legitimate interest request for every single record. You will only be able to search for a business. So you might know the person's name, but you can't use that to search. You will have to somehow try to figure out what businesses you think they are already connected with in order to do the search. You will have to then pay a fee. I think it's about 70 or $75 per search. Um, and the person or business that you are requesting information about, um, has a right of reply and has an opportunity to be informed that you are asking for that information and then object to you having it. That's an extreme example of how a legitimate interest access regime is likely to lead to absolutely zero use and usability. On the other end of the spectrum, you have ideally a public regime, but where perhaps there's a legitimate interest access regime, you have what is suggested under the Sixth Anti-Money Laundering Directive, which is that you apply once in one member state. That legitimate interest access, uh, right will carry on for a couple of years, and then you will reapply. You can pretty much take and get all the records that you need. Um, so they're just two ends of a particular spectrum here, and that's really just on the issue of search and, and what kind of data you can get. To make data truly usable, um, it does need to be well-structured. Um, it needs to be structured in a format that's well explained and well documented. Um, we need to make sure that a company has a unique identifier. We need to be able to make sure that we can uniquely identify a natural person, you know, we have enough information to disambiguate, um, with people that may have a s- the same or similar name. So there are a whole range of different things that think-- we talk about usability, and, and what we've done in our usable data framework is to try and break out what those features are of usability kind of across the sort of way you access and use the data. So it lays out what good search looks like, the kind of good... the useful and most helpful ways you can search for beneficial ownership information, all the way through to talking about the features of the data structure that make it usable and interoperable. This sounds, uh, what you described in the beginning, the, these, these registries where, where you can search by name and get all the companies, uh, that the individual is affiliated with. That sound, that sounds like a dream for- Yeah ... I think journalists or even people that, uh, work in our s- our space in, uh, due diligence, KYC checks. This is, this is, this is something we, we often dream, dream about. Are there actually some examples of, uh, registries, uh, that work in this way? The UK would be one, Nigeria, um, a few other jurisdictions around the world. Canada will, should at, at federal level. Um, can already at provincial level to some degree. Um, I think if you, if you sort of look around the world, I think particularly there's lots of e- examples of registers being built now in, in sub-Saharan Africa. I think of, um, Botswana has a really, really effective public register of beneficial ownership. If you go on there, it's data structured. They've used our data standard, the beneficial ownership data standards to structure that. So it is out there and you can go and see it and you can go and use it. Um, the challenge is always one of adoption. I think we sort of want to be able to feel confident that for the most part, whichever country we go and look for data, we'll find it. That is, that is not the case. Um, but yeah, there are lots of examples out there of, of this being done well, and it's not-- I don't think it's that hard to do it well once you've got the information into your system to structure it effectively and provide a method of access which actually delivers results for people, I think is, is quite easily done. Um, I'd say also like it, it-- framing kind of really good search and access as a sort of issue only, uh, for NGOs and investigative journalists kind of misses the point about what everyday due diligence outside of being an obliged entity looks like. Do I want to find out who I'm working with in any kind of contract or who I'm buying from, and can I do that quickly as a business? In most jurisdictions, the answer is no, and I've always found at the core of this a really weird paradox. We, we want businesses to be as well-informed as we possibly can about who they are, and we ask them to do due diligence on people, yet we seem to have designed a regime that, that makes that really quite difficult and expensive. So I've, I've always struggled with the, the, the, the, the weirdness of that, this idea that you have an obligation to, to do your due diligence, yet as a society, we're gonna, we're gonna make that as hard as possible for you. Very strange. Yeah. That's a, that's a, that's a really good point. Have you, by the way, worked with, uh, some, maybe some of these, uh, jurisdictions that you described that have this, uh, this very e- e- effective, uh, beneficial ownership registries in place? Yeah. We, we have. I mean, I, I, I'd, I'd probably l- I'd probably turn to Nigeria at this point 'cause I think it's such an interesting-- such a, such a large, vast economy and such a big population, and they've really been doing beneficial ownership reform for, well, more than 10 years now. Um, I think it was the, the 10th of May 2016 that the, the now sadly, um, uh, former, uh, deceased Vice President, um, Tinubu came to London for that anti-corruption conference that we spoke about, um, at the beginning and said, um, "We're going to implement beneficial ownership reform. It's gonna be public, and also we would like our money back." So saying that to, to London and the London property market. It was kind of a really big moment, I think, um, politically for this issue. So Nigeria's been doing this work for a long time. They have a public register. They have good structured data on beneficial owners. They've also done a really, really good job of cleaning up their, their corporate registry and removing a lot of dormant companies, hundreds and thousands of dormant companies. Um, so now there is public access to this information. The methods of verification are getting better. There's more work to do. There's more work to make sure it's fully connected up to the national identity card system so that when a Nigerian national, um, either provides information or updates it, you can check against the national ID register that that's, that's, um, that's been effectively verified. And it's being used. Um, it's being used in investigations. It's being used to ensure that, um, where minerals, um, mineral licensing rights are being issued, they are going to non-politically exposed people. Day in, day out in Nigeria, it, it's, it's happening, and I think the, the public really welcomes it. Um, and there's still more work to do. Nigeria was one of the kind of first movers, really, so it's had to, it's had to learn. We've, we've been delighted to work alongside them for the last 10 years sort of implementing this work. And t-talking about, uh, kind of the public perception of this area, the, uh, phase one of the, I think the biggest criticism of beneficial ownership registers is the fact that people can simply lie, uh, with regards to the data that they provide, uh, to the authorities. Who should be, uh, responsible for the verification, or who is actually responsible for veri-verification in, in the countries that you, uh, work with, in the registries that you are kind of familiar with? Yeah, it's a really good question, and I think the first thing to say is the way that we think about verification is that, um, it, there, there are two parts to the problem. One is about how you verify the identity of a, of a natural person, of an individual. That's quite straightforward in most jurisdictions now. Many countries have a national ID card system. You can provide passports. There's, there's more you have to do to make it work really, really well, but that, that's a problem we figured out how to solve for the most part. The other challenge, which is far harder to solve, is how do you verify that the statement someone gives about what they own and control is real. How do you verify that? And that problem splits out into a couple of different things. The easiest type of control to verify is share ownership. There's a certificate. Clearly, publicly listed companies sit outside of all of this because you know the owners. Um, so you have a shareholder register. That's quite straightforward, and your, your claim to ownership is, is in a certificate. Um- What's far harder to verify are other types of control, particularly nominee arrangements, um, situations in which, um, a spouse or partner is named as the beneficial owner, but really the-- it's the, the other side of that relationship which is, um, which is, you know, doing the work, exercising the beneficial ownership. So how you do those things, I think is far harder. Countries that do it well, I'd pick on Austria, um, they've recently had their, uh, the publication of their FATF mutual evaluation. They, they do a really good job of verifying. It's a mixture of, um, I think, quite private techniques that they use to look at the data, but there's also quite a lot of random sampling, so they're picking out a hundred, two hundred, three hundred companies per year, doing site visits, then talking and reporting that as well. So there's a big aspect of that approach, which is deterrence. This idea that, you know, every year when you could be in the sample, you know, and if you lie about it, then you could get in quite a lot of trouble. Um, so that's a sort of good approach. Uh, the, the key message I think for, for, for people thinking about this is that verification, particularly of status of beneficial ownership, really is kind of a team sport. Um, we have discrepancy reporting, of course, so obliged entities suggesting where they think data is incorrect. We also need to create a culture across government of better data sharing between departments to help with verification. And I think one of the key areas we need to look at more data sharing or information cross-checking, uh, is with tax systems. So if a person is listed in your beneficial ownership register as the beneficial owner of a company worth a million dollars and they own twenty-five percent of it, do they appear in your tax record? 'Cause if they don't, we have the owner of a company, we have a, we have an owner of something with a value of two hundred and fifty thousand dollars who somehow isn't in your tax record. That's probably worth investigating. In lots of jurisdictions, that kind of thing is a, is a red flag for what we call fronting, so just putting someone on paper as the, as the owner of the business. Um, we can connect to, you know, movable property registers, uh, land registries, which has happened a lot more in the UK now. We have a, a register of overseas owners of, of land and property in the UK. So there's lots that can be done, but it requires coordination, cross-government working, better information sharing. Um, and I think a realization that the goal is not to get to complete certainty, but to make sure that data is good enough for what you need to use it for. Um, yeah, it's-- there's a lot, there's a lot more we need to be doing, but progress is happening and it, and it is what people care about because Recommendation twenty-four of FATF says very clearly that data has to be accurate I'm up to date. And it will be in the next couple of years that we really begin to find out what they mean by it. And I think that's the critical thing. What does FATF think verified means? And we'll find that out in the next few years. A- and speaking of progress, are there, uh, there any examples of countries, you already mentioned Nigeria and, uh, so you just mentioned Austria, but, uh, maybe, uh, some other countries where you see the most progress and vice versa in this regard? Um, I think Denmark does a really good job as well. Um, really, really high levels of accuracy, we think. Um, again, a mixture of their own proprietary approaches, but also, um, this, this, this sampling effect and telling people that we will come and investigate you. Um, Norway doing some, some good work on this as well. Um, really just giving their analysts quite a kind of broad, um, range of data to, to be able to look at. I mean, uh, Norway's a particularly interesting case because there's a high degree of transparency around tax data already, so you have that ability to interlink. Um, so, so Norway is a, is an absolute leader on all of this, but perhaps that model isn't replicable everywhere given the, the kind of uniqueness of its approach on tax. Um, other countries as well that I think are doing good jobs, the South Africans are doing a, a really, really good job on, on, on AML generally. Um, and that's really through f- less of a public approach on this data, but a much more, um, connected approach to data across government. Um, I don't think this is necessarily completely or fully connected to the money laundering, um, efforts that South Africa have made, but they're really beginning to see their tax revenue go up 'cause they've got a better tax system. There's more connected data. They're able to identify avoidance and evasion better. So the connection of government data done with, you know, a proper understanding of what privacy and data protection need to look like in a jurisdiction, done well, really can deliver results and more money. Um, but it, it takes time. Um, so I'd point to South Africa for sure. And I think actually if you look at some of the, um, some of the, what we suspect is some of the best data on beneficial ownership in the world, that's, that's held where, um, the beneficial ownership register is, is run by the tax authority. So Argentina's a good example. Unlike most of the world, quite a number of countries, um, in, in Latin and South America have their tax authority as the, as the owner of that. So they are s- already starting from a, a, a more data-rich environment because they, they have tax data. The downside of that is, of course, that beneficial ownership information in those jurisdictions is as restricted therefore as tax information. So less usable, but we think probably far higher quality because of where it's coming from. Hmm. Uh, let me ask you this one last question, Tom, uh, 'cause I feel like there has been, in the European Union at least, quite a lot of skepticism, uh, in the regard to, uh, beneficial ownership transparency, but also like corporate- Transparency more broadly, I think since, at least since the 2022, uh, court ruling that we just discussed in the beginning. But you, you have a much more broader perspective. You're looking at this really, really globally. Uh, are you as skeptical or have you been seeing kind of more progress than regress over the past, let's say, five, 10 years? It's definitely, it's definitely more progress. Um, we have gone from a small handful of countries committing and beginning to implement this work 10 years ago, eight years ago, to today where depends how you count it, but about 150, 160 jurisdictions have either done this work, are doing it now or plan to do it. So the graph is very, very steep in terms of progress. I can't think of another policy area that has experienced such a rapid increase around delivery. So I think progress is absolutely there. The challenge becomes, of course, well, what kind of systems are they implementing? Are they going to be good? Are they gonna be usable? Are they gonna be accessible? Um, we have a lot of the data of it on that at Open Ownership. We maintain a, a map on our website that tries to capture what that implementation journey looks like across the world. And underneath all of that are a huge number of indicators about what the system looks like. So we're trying our best as an organization to keep, keep a kind of clear eye on all of this. I can say with, with huge confidence the, the level of investment in this work is far higher than it used to be globally more because more countries are doing it. As I say, lots more countries are doing it. But I think the kind of awareness and understanding of why this matters, um, has grown significantly over time. And I think as the space has matured, as we've had the Sovim decision in 2022, we've had AMLD6, we've had the rollback of the Corporate Transparency Act in the US, and lots of other things happening, like the debate is a lot more interesting now. People understand what the concepts are. We can point towards different models of implementation and debate the relative merits of them. Um, we are building up the evidence base rapidly. Um, we held a research symposium as Open Ownership alongside the World Bank and the UK government back in February. Um, we had nearly 100 participants from around the world coming to talk about their research or applying to come and talk about their research into beneficial ownership and how it operates. So the research community is far bigger than it ever used to be. Even two, three years ago, you'd only find one or two papers a year, so that's really going up as well, which indicates that there's more material to work with. So I think wherever you look there is positive progress, but as with all policy reform, the real story is many layers beneath all of that, and it's going to take a few years to really know where all of this work comes out. But be under no illusion, the work is happening, the reform is happening. It's all of our jobs to scrutinize that work, suggest how it needs to be better, and then advocate for governments who want to do a good job to, to invest in it and do the work well over the next decade. Well, this, this sounds, this sounds really, really, really good. Uh, it's been really, uh, fascinating to get your perspective on this, on, on the subject, Tom. So thank you so much for finding the time and coming on the podcast. I really appreciate it, and I wish you all the best with your efforts. It's my pleasure. Thank you for having me.