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openownership / data-standard

The Beneficial Ownership Data Standard (BODS) is an open standard providing a specification for modelling and publishing information on the beneficial ownership and control of corporate vehicles
http://standard.openownership.org
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Documentation: how to represent intermediary actors such as accountants and lawyers in BODS #626

Open StephenAbbott opened 7 months ago

StephenAbbott commented 7 months ago

Is your request related to a problem? Please describe. Publishers of beneficial ownership information sometimes want to differentiate between beneficial owners themselves and professional intermediary actors (accountants, lawyers, etc...) acting on behalf of the beneficial owners.

To capture these relationships in BODS, publishers should use an entity with type 'arrangement'. Then both the intermediary agency and the client entity should be interested parties in the arrangement. This is akin to how to represent nominee relationships in BODS (see https://github.com/openownership/data-standard/issues/329 and documentation).

The interest type used to explain the relationship between the entity and the intermediaries/beneficial owners will then depend on what it is that the intermediary is doing for the beneficial owner.

We should bear this user need in mind when working on https://github.com/openownership/data-standard/issues/466 at a future date.

What publishers and users of beneficial ownership data would be benefited by adding this feature? The need for better documentation in BODS came about during a conversation with the International Consortium of Investigative Journalists when discussing their Offshore Leaks database.

Offshore Leaks data is formatted in line with Neo4J and example data packages can be found at https://github.com/ICIJ/offshoreleaks-data-packages.

Here is an image showing how ICIJ currently represents intermediaries in Neo4J: Screenshot 2024-01-18 at 17 49 25

Thanks to Open Ownership's partnership with the OpenSanctions team, you can see the full range of intermediary roles that ICIJ uses at https://github.com/opensanctions/opensanctions/blob/main/datasets/_global/icij_offshoreleaks/icij_offshoreleaks.yml#L33-L489 which is code used by OpenSanctions to map the ICIJ Offshore Leaks data to the FollowTheMoney data model used by OpenSanctions and OCCRP.

kd-ods commented 7 months ago

To capture these relationships in BODS, publishers should use an entity with type 'arrangement'. Then both the intermediary agency and the client entity should be interested parties in the arrangement. This is akin to how to represent nominee relationships in BODS (see https://github.com/openownership/data-standard/issues/329).

Alternatively, there may be cases where the 'intermediary' is doing little more than meeting obligatory reporting requirements on behalf of their client. In terms of BODS modelling, the intermediary would then appear as an agent in the source.assertedBy array.

StephenAbbott commented 4 months ago

Last week, Open Ownership and Open Data Services released version 0.4 of the Beneficial Ownership Data Standard https://standard.openownership.org/en/0.4.0/

As part of this release, we published documentation about how to represent nominee arrangements in BODS https://standard.openownership.org/en/0.4.0/standard/modelling/repr-nominations.html

This same approach could be adapted - as noted above - to allow for the capturing of data on anyone who the beneficial owner has a legal arrangement with, including accountants or lawyers.