Feature: Representing assets

[kd-ods]

[This ticket helps track progress towards developing a particular feature in BODS where changes or revisions to the standard may be required. It is on the BODS Feature Tracker.]

Feature background

What user needs are met by introducing or developing this feature in BODS?

BODS has been developed so that information about how legal vehicles are owned and controlled can be shared between systems. Legal vehicles include legal entities like companies, trusts and other legal arrangements. The primary collectors and publishers of related information are likely to be corporate registries and regulators.

This information can be connected with external information about the assets connected to legal vehicles. However, assets cannot themselves be represented in BODS format, nor relationships with those assets.

Open Ownership has seen a number of projects which aim to establish beneficial ownership transparency for assets in a given class, and to share that information. The common user need here appears to be: to ingest or publish structured data about how an asset or assets are linked to a beneficial ownership network.

Asset class: mining and drilling concessions

The Extractive Industries Transparency Initiative (EITI) requires that the beneficial ownership of companies that apply for or hold extractive licences, contracts, or concessions be disclosed.

Asset class: media brands/outlets

The Euromedia Ownership Monitor “provides a searchable database of media owners with several features, such as visualisation of ownership networks.”

Asset class: Energy production

Global Energy Monitor’s Global Energy Ownership Tracker “provides information on the chain of ownership for various energy projects. The data maps each level of the chain from the direct owner (as in, the lowest-level identified owner in the chain of ownership) up to their highest-level ultimate parents (e.g., corporations, investment firms, and governments).”

Asset class: Vessels (fishing and shipping)

Civil society organisations like Global Fishing Watch are pushing for greater transparency around beneficial ownership of vessels and fisheries. C4ADS developed Triton which brings together finishing vessel data with information about "the companies that ultimately control them", enabling network visualisations and analytics that reveal vessel ownership structures.

Asset class: Bank accounts, securities and other financial assets

The EU's Sixth Anti-Money-Laundering Directive (AMLD6) mandates “timely access to information on the identity of holders of bank accounts and payment accounts, securities accounts, crypto-asset accounts and safe-deposit boxes, their proxy holders, and their beneficial owners”.

The OECD’s Common Reporting Standard (CRS) allows participating jurisdictions to automate information-sharing about the holders and ‘controlling persons’ (beneficial owners) of financial accounts.

Asset class: mixed

Other cases where it could be useful to see assets linked to their beneficial ownership network (in a single data format) extend across asset classes. For example, high net worth individuals and those who manage their wealth may need to capture and transfer information about how legal vehicles are employed across jurisdictions and are linked to their assets.

Similarly, law enforcement and taxation authorities (driven by anti-money-laundering, anti-corruption or resource mobilisation priorities) undertake investigations where it’s critical to understand how a variety of asset types are controlled and used via a common network of legal vehicles. Transferring, collating, and analysing network information as structured data are necessary steps in such investigations.

Civil society organisations such as Transparency International and members of the Tax Justice Network have a similar interest in understanding the networks of legal vehicles which are used to manage assets.

What impact would not meeting these needs have?

Leaving assets out of the data standard would not have a negative impact. BODS would be left as a data standard for beneficial ownership of legal vehicles only.

Asset information, along with good identifying information for legal vehicles with interests in the asset, would need to be maintained elsewhere (e.g. an asset register or dedicated database) and then joined with BODS data. BODS being able to represent assets is not so useful in such a case.

For use cases where people want to understand how mixed assets are controlled by a single corporate network, BODS being able to represent assets would be more useful.

How important is it to meet the above needs?

There are other data models, like FollowTheMoney which have greater scope to cover assets and which include legal vehicles.

How urgent is it to meet the above needs?

Not currently urgent

Are there any obvious problems, dependencies or challenges that any proposal to develop this feature would need to address?

One modelling consideration would be how to handle assets which are based on the equity and control of legal vehicles; for example: shares, options, or units in an investment fund. These are assets which often underpin the relationships between legal vehicles and legal vehicles, or people and legal vehicles. These assets are already implicitly represented in BODS as types of interest. If they were represented as distinct asset objects in an updated BODS data model, the modelling would be to a finer resolution, but - in most cases - to little benefit and at the expense of simplicity. If that reasoning holds, then the implication would be: continue to represent such financial assets as types of interest in legal vehicles (i.e. a property of relationships). BODS asset objects would only represent assets which are not derived from legal entity ownership or control (for example: land, vessels, bank accounts).

A further modelling consideration would be the level of detail which BODS could hold about assets. Given the range of asset types, a minimal implementation would probably be advisable (e.g. having assets be a BODS record type, and the required fields being only assetType, assetId, and assetName). This being alongside the expectation that asset registries (such as land and property registries) maintain more detail.

Feature work tracking

[Link to proposals, bugs and issues in the repository to help track work on this feature]

[kd-ods]

We'd love to hear any reflections and opinions on this potential feature. The above problem statement can be edited to incorporate further context, use cases, and considerations.

[talestomaz]

This is a good consideration.
From a non-technical background: I think there's room for formalising assets in the standard, but leaving the details for own implementation. Take EurOMo and media outlets as an example. Indeed, what we need in terms of asset details goes way beyond what BODS currently offers. This is a level of detail and specificity that problem makes little sense for other assets, and there's no point of trying to cover it. I imagine the same goes for other use cases.
If we can indeed indicate the asset owned providing very basic information, but there are good instructions (standards?) on how to expand it on our own (is it the addition of a new table matching the asset of ID (like in EurOMo)? Is it the addition of columns? Is it another spreadsheet?).
It goes without saying that, for our use case, the ability to provide data with spreadsheets is crucial. Our data collectors (and even we in the management) have no idea how we would begin otherwise.
Thanks!

[kd-ods]

Thanks for these thoughts, @talestomaz!

indicate the asset owned providing very basic information

It's useful to have your endorsement of this approach.

for our use case, the ability to provide data with spreadsheets is crucial

It's good to have this need noted here on GitHub. I imagine that yours is not the only research project handling beneficial ownership information which has this requirement.