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The article analyses the key issues in the implementation of the new corporate ownership and beneficial ownership disclosure obligation introduced by the fourth EU Anti-money Laundering Directive. It discusses some of the immediate and potential issues arising from the interlinked problems of effectiveness and efficiency of identification and evidencing of corporate ownership structures and beneficial owners, and comes up with a possible comprehensive solution for these issues which consists in developing a practical guidance on disclosure of corporate and beneficial ownership structures. This guidance—in the Practical Guide on disclosure and evidencing of corporate and control structures and beneficial owner(s) for the process of verification of disclosed ownership structures and beneficial owners, and in the Handbook for disclosure of beneficial ownership and beneficial owners for the process of investigation of unknown ownership structures and beneficial owners—would elaborate in detail the provisions of the guidance on transparency of beneficial ownership issued by the Financial Action Task Force.
