The End of the (Third Party Management) World As We Know It? (But It Might Be Fine)

On November 22, 2022, the Court of Justice of the European Union (CJEU) ruled that EU legislation requiring public access to beneficial ownership registers was invalid. The CJEU’s decision goes against the grain of international progress towards greater corporate transparency over the last decade and has prompted widespread concern about its impact on anti-bribery and corruption and anti-money laundering efforts. The decision restricts access for businesses who conduct financial crime due diligence, by requiring them to prove they have a legitimate interest in accessing the information. See “Making Corporate Transparency a Global Norm” (Sep. 4, 2019).

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