REPORT TO CONGRESS ON

BENEFICIAL OWNERSHIP INFORMATION 

PRACTICES AT THE MULTILATERAL 

DEVELOPMENT BANKS

A Report to Congress 

in response to

SEC. 7029(f) of the Further Consolidated Appropriations 

Act, 2020

United States Department of the Treasury

June 2020
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Report on Beneficial Ownership Information Practices at the 

Multilateral Development Banks

June 2020

Introduction

The Treasury Department presents this report on Beneficial Ownership Information Practices at 

the Multilateral Development Banks (MDBs) in compliance with section 7029(f) of the Further 

Consolidated Appropriations Act, 2020, P.L. 116-94. This report provides an update to the 

policies and practices that the MDBs have implemented over the past fiscal year to enhance

disclosure of beneficial ownership information in their respective institutional operations.

SEC. 7029(f) BENEFICIAL OWNERSHIP INFORMATION. — The Secretary of the 

Treasury shall instruct the United States executive director of each international 

financial institution to use the voice and vote of the United States to encourage such 

institution to collect, verify, and publish, to the maximum extent practicable, beneficial 

ownership information (excluding proprietary information) for any corporation or 

limited liability company, other than a publicly listed company, that receives funds from 

any such financial institution: Provided, That not later than 45 days after enactment of 

this Act, the Secretary shall submit a report to the Committees on Appropriations on 

steps taken in fiscal year 2019 by the United States executive directors and the 

international financial institutions consistent with this subsection compared to the 

previous fiscal year.

Below are brief descriptions of the beneficial ownership information practices at each of the 

MDBs, emphasizing recent updates and recent efforts by the United States’ Executive Directors.

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All the MDBs recognize the importance of the legislation and are striving to respond to the 

legislation. The MDBs are strong proponents of disclosure and access to information, largely as 

a result of strong U.S. encouragement to do so.

Developments in Beneficial Ownership Information Practices in the Multilateral 

Development Banks (MDBs)

International Bank for Reconstruction and Development (IBRD) and the International 

Development Association (IDA)

The World Bank (referring to IBRD and IDA) continues to monitor implementation of its 

Beneficial Ownership pilot launched on November 1, 2017. The pilot covers the World Bank’s 

fiscal years 2018 through 20202 and publishes beneficial ownership data for the winning bidders 

of procurements over certain thresholds (subject to review by the Operational Procurement 

Review Committee) financed by World Bank projects. These procurements are expected to 

represent approximately 40 percent of all Bank-financed procurements by value. World Bank 

 1 Please see the 2018 Report on Beneficial Ownership Practices at the Multilateral Development Banks for greater 

context about beneficial ownership: https://www.treasury.gov/resource-center/international/developmentbanks/Documents/Report_to_Congress_on_Beneficial_Ownership_at_MDBs_August_2018.pdf

2 The World Bank’s fiscal year runs from July 1-June 30.
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Management will review and report to the Board of Directors on implementation progress, 

including any lessons learned, during the World Bank’s fiscal year 2021. 

Under the pilot program, the World Bank’s standard procurement documents require winning 

bidders to identify beneficial owners using thresholds for determining ownership and other 

definitions of control developed by the Financial Action Task Force (FATF). Borrowers are 

required to publish beneficial ownership information, along with other contract award 

information, on their websites, and the information is published on the World Bank’s website.

One of the objectives of this pilot is to contribute to a level playing field for companies with 

sound corporate governance structures and high integrity standards. To date, the World Bank 

indicates that the response to the pilot has been positive.

The pilot’s beneficial ownership requirements began to be applied to contracts awarded in 

projects approved after November 1, 2017. As of January 2020, beneficial ownership 

information has been disclosed for two eligible, awarded contracts with a combined value of 

approximately $1.21 billion. Beneficial ownership information for these contracts was published 

in United Nations Development Business (UNDB, URL: www.devbusiness.com) and the World 

Bank’s external website (www.worldbank.org). The procurement processes for additional

contracts are currently under way and beneficial ownership information will be published when 

the processes are completed. 

The World Bank may conduct verification of beneficial ownership when integrity red flags are 

triggered or in other cases when extended due diligence is warranted. Misrepresentation of 

beneficial ownership information by the winning bidder may constitute a sanctionable offense 

under the Bank’s Anti-Corruption Guidelines and will be reported to the Bank’s Integrity Vice 

Presidency which may conduct a fraud investigation potentially leading to the company’s 

debarment.

The Beneficial Ownership pilot is part of the Bank’s strategy to enhance transparency and open 

contracting. The Office of the U.S. Executive Director has supported this effort and sought 

regular briefings to remain aware of the pilot’s status. The Office of the U.S. Executive Director 

continues to advance United States policy in this area and consistently presses for integrity, high 

due diligence standards, and robust information disclosure in all projects. The World Bank has 

shared information about this pilot with other Multilateral Development Banks interested in 

launching a similar program and has actively discussed it with a broad range of stakeholders, 

including the U.S. Treasury and U.S. companies. As noted later in this report, other MDBs are 

starting to pursue similar processes.

International Finance Corporation (IFC)

The International Finance Corporation (IFC) is the part of the World Bank Group that invests in 

private sector entities conducting business in emerging markets and developing countries. 

Before it makes an investment, IFC identifies all parties with a substantial interest in the entity.

Generally, IFC identifies and conducts integrity due diligence (IDD) on those entities and 

individuals who own or control ten percent or more of an entity (where possible, IFC identifies 

and conducts IDD on those who own or control five percent of an entity), including indirect and 
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ultimate beneficial owners, as well as the top five direct owners as applicable. If the company is 

a fund, IFC also conducts IDD on the general partner or fund manager, even if the general 

partner/fund manager does not meet those thresholds, as well as the general partner/fund 

manager’s direct owners down to the five percent level and top five owners. 

IFC staff conducts IDD, using various sources, to identify whether there are any integrity risks in 

the project. It conducts IDD on key entities and individuals involved in the project; IDD is not 

limited just to the contracting party. IFC defines “integrity risk” as any risk involved in 

engaging with entities or persons whose background or activities may create a risk of adverse 

reputational and, often, financial impact on IFC. All clients in the portfolio are screened daily by 

a computerized screening system against various enforcement lists. IFC’s compliance team 

periodically reviews certain projects to ensure that the IDD processes have been properly 

followed. 

IFC posts project descriptions on its website, which may also include the names of sponsors and 

major shareholders in the project company and other key entities, including beneficial ownership 

information where relevant or appropriate. In the most recent fiscal year, IFC has also 

strengthened periodic reporting of integrity risk issues to management, the Audit Committee and 

the Board as part of improvements to strengthen its IDD processes. The Office of the United 

States Executive Director has encouraged these efforts and the U.S. Treasury staff has also 

emphasized to IFC management the importance of increased transparency, particularly with 

regard to IFC’s investments in financial intermediaries. 

The Multilateral Insurance Guarantee Agency (MIGA)

There are no significant changes to report since last year’s report. The Multilateral Insurance 

Guarantee Agency (MIGA) is the part of the World Bank Group that provides political risk 

insurance and credit enhancement guarantees to protect foreign direct investments against 

political and non-commercial risks in developing countries. Like the IFC, MIGA identifies 

beneficial owners and conducts integrity due diligence on project entities and individuals with a 

substantial interest (i.e. five percent threshold). MIGA continues to use computerized screening 

systems for efficient and timely project monitoring for emerging integrity risks. The Office of 

the U.S. Executive Director continues to review the results of MIGA’s integrity due diligence as 

individual projects are considered for Board approval and stays closely engaged with MIGA 

staff. 

European Bank for Reconstruction and Development

The European Bank for Reconstruction and Development (EBRD) invests in private sector 

entities and provides loans to sovereign governments. Its approach towards beneficial ownership 

remains largely consistent with last year’s report. Awareness of beneficial ownership is the first 

of the EBRD Integrity Due Diligence (IDD) guidelines. All staff involved in EBRD projects

undergo in-person training on these guidelines. Like the other MDBs operating in the private 

sector, the EBRD conducts risk-based IDD on the companies in which it invests. EBRD staff is 

responsible for collecting and vetting beneficial ownership information based on information 
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gathered through site visits, discussions with the client, and general knowledge of the 

region/sector, as well as Bank for International Settlements searches. 

In more complex cases the EBRD will commission a confidential external due diligence 

report. The EBRD will not proceed with a transaction without knowing who the beneficial 

owners are. Additionally, investments that involve politically exposed persons, clients with poor 

past business practices, or other high-risk clients will trigger enhanced IDD. The EBRD 

publishes information on its project partners. The EBRD publishes beneficial ownership 

information where practicable. The EBRD identifies all the beneficial owners in projects being 

considered for Bank involvement (unless the number of small shareholders makes this 

impractical, or where a company’s ownership is identified as being very fluid). The EBRD uses 

the FATF definition of beneficial ownership: 

“Beneficial owner refers to the natural person(s) who ultimately own(s) or control(s) a 

customer and/or the natural person on whose behalf a transaction is being conducted. It 

also includes those persons who exercise ultimate effective control over a legal person or 

arrangement.”

In addition, the EBRD has carried out additional activities to help support efforts to improve 

collection, verification, and publication of beneficial ownership information. This includes 

serving as an observer at the FATF, the Eurasian Group (or “EAG” which is the Eurasian FATFstyle regional body), and Moneyval Plenaries (a Council of Europe permanent monitoring body 

referred to as “the Committee of Experts on the Evaluation of Anti-Money Laundering Measures 

and the Financing of Terrorism.”). The EBRD has applied to become an observer at 

MENAFATF (the MENA region’s FATF-style regional body) and is part of the FATF working 

group to enhance MENAFATF’s development. EBRD has organized donor-sponsored capacity 

building in their countries of operation, and engaged in high-level events to further the 

importance understanding of the concept of beneficial ownership.

In 2018, the U.S. Executive Director’s office pushed EBRD to add language on contract 

disclosure to its new Access to Information Policy (due to replace the Bank’s Public Information 

Policy), the final version of which was approved in 2019 and came into effect on January 1, 

2020. The U.S. Executive Director’s office continues to monitor this topic and engage with 

EBRD Management on requirements regarding accountability and transparency, including the 

collection, verification, and publication of beneficial ownership information related to extractive 

industries and on-site project monitoring.

African Development Bank

The African Development Bank (AfDB) provides both sovereign and private sector lending. The 

AfDB is now implementing its revised procurement policy (updated in 2015) that improves its

approach to the collection and publication of beneficial ownership information in the 

procurement process for sovereign operations. The new AfDB Operations Procurement Manual, 

which is publicly available, includes a section on beneficial ownership. In addition, the AfDB 

has developed a guidance note on beneficial ownership and politically exposed persons, which is 

part of the Procurement Toolkit that complements the revised procurement policy.
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The new Operations Procurement Manual and the accompanying guidance note were prepared in 

close partnership with the World Bank, and the approaches followed by the two MDBs are 

closely aligned. Like the World Bank, the AfDB now requires that a successful bidder under an 

AfDB-financed contract above a specified monetary threshold disclose publicly its beneficial 

owners. Beneficial owners are defined as any individual—or closely related individuals—who 

own or control 25 percent or more of the voting shares of the firm. This information will then 

published by the AfDB and the borrower. The AfDB will consider the failure to provide this 

information or the provision of incorrect information as a potential misrepresentation that may 

result in disqualification or other appropriate sanctions. 

For private sector projects, like the other MDBs, the AfDB conducts standard integrity due 

diligence and enhanced due diligence, as appropriate, for all clients and their ultimate beneficial 

owners, as guided by its Integrity Due Diligence Policy on non-sovereign operations and other 

applicable Bank policies and procedures. The AfDB screens all clients and all beneficial owners 

on all non-sovereign operations against all relevant lists. The Bank collects this information and 

discloses that which is practicable and that which is allowed under its disclosure policy. 

The Office of the U.S. Executive Director continues to advance United States policy in this area 

and consistently presses for integrity, high due diligence standards, and robust information 

disclosure in all projects. The Office has worked closely with AfDB management in the 

development of the Operations Procurement Manual and is continuing to work with AfDB 

management during the roll out and implementation of the manual. The Office of the U.S. 

Executive Director has also promoted greater upstream involvement of the AfDB’s Integrity and 

Anti-Corruption Department in the Integrity Due Diligence in individual projects. 

Asian Development Bank

The Asian Development Bank (AsDB) provides both sovereign and private sector lending. The 

AsDB’s requirements related to beneficial ownership information focus on its private sector 

operations. AsDB rules require staff to carry out Integrity Due Diligence (IDD) and identify one 

hundred percent of the beneficial ownership of a company. AsDB staff then verifies these 

owners through a desk review of the potential client using corporate registries, open and closed 

source databases and various search engines. Like other MDBs, AsDB staff screen potential 

counterparties and their beneficial owners against relevant lists.

Where there are shareholdings of five percent or more that are not identified or the owners of 

which remain unknown, or where shareholdings in publicly listed companies of ten percent or 

more are not identified, the Board is informed. Beneficial ownership information is published, to 

the extent practicable, whenever the beneficial owner’s shareholdings are discussed in the 

documents that are approved by the Board (referred to as the Report and Recommendation of the 

President).

In sovereign projects where the executing agency or implementing agency is not a government 

ministry or agency, the borrower must identify any beneficial owner that is not state-owned. For 

the procurement for sovereign projects, the bidding process is governed by the AsDB’s 
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procurement guidelines, which adopt international standards on bidding, focusing on bidder 

eligibility, technical qualifications and financial proposals. Bidders are checked against AsDB’s 

debarment list before being awarded a contract, as is done in other MDBs. Similar to other 

MDBs, the AsDB’s debarment list includes firms that have been cross-debarred in accordance 

with the "Agreement on Mutual Enforcement of Debarment Decisions" among AsDB, EBRD, 

World Bank, IADB and AfDB. AsDB is monitoring the World Bank’s ongoing pilot on the 

disclosure of beneficial ownership in high value procurement. 

The Office of the U.S. Executive Director continues to advance United States policy in this area 

and consistently presses for integrity, high due diligence standards, and robust information 

disclosure in all projects. In late 2018, the Office of the U.S. Executive Director requested that 

AsDB’s Office of Anti-Corruption and Integrity and Private Sector Operations Department 

update the Board of Directors on Integrity Due Diligence (IDD) for non-sovereign operations 

and the implementation of AsDB’s tax integrity policy – a key component of transparent 

beneficial ownership. 

Inter-American Development Bank

For the Inter-American Development Bank’s (IDB) sovereign operations, governments borrow 

the funds and then enter into procurement contracts with companies to carry out the development 

activities. Procurement arrangements are conducted by the borrowing governments in 

accordance with IDB procurement policies. The IDB publishes procurement data on its website 

for contract award winners (for public works, goods and services procured through international 

competitive bidding or amounting to US$25,000 or more, as well as for all consulting 

contracts). Information published includes the name of the firm, its location and the value of the 

contract. 

With respect to beneficial ownership, there has been significant progress since last year’s 

report. The new procurement policies of the IDB were approved in 2019 and took effect January 

1, 2020. They require that in international competitive bidding processes, executing agencies 

request beneficial ownership information from each company being recommended for award 

before the publication of the award of the contract. Per these new procurement policies, the 

information that shall be requested includes the names of “Beneficial Owners” defined 

as individuals who directly or indirectly: (i) hold 25 percent or more of the shares of the 

company; (ii) hold 25 percent or more of the voting rights; or (iii) have the right to appoint a 

majority of the board of directors or equivalent governing body of the company selected for the 

contract award. This information will be published by the borrower on the United Nations 

Development Business (UNDB) website and will be forwarded for publication on the website of 

the Bank.

IDB Invest

The Inter-American Investment Corporation (IDB Invest) is a member of the IDB Group. It 

lends to and invests in private sector companies that conduct business in its regional developing 

member countries. Like other MDBs investing in private sector entities, IDB Invest identifies 
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and conducts integrity due diligence (IDD) on entities and individuals related to IDB Invest 

projects. 

The IDD process is established in its Integrity Framework which states:

“A cornerstone of integrity risk management is to ‘know your customer’. This 

requires the [IDB Invest] to conduct and regularly update, with the support of 

[the Office of Institutional Integrity], appropriate due diligence on its potential 

clients, existing clients and projects, as well as associated individuals and 

relevant related parties. Core elements of this review shall include . . . identifying 

and screening ultimate beneficial owners.”

IDB Invest has also established internal Integrity Due Diligence Guidelines which govern the 

IDD process at a more granular level, and which define “Beneficial Owner” as follows:

“A ‘Beneficial Owner’ is a natural person or legal entity that ultimately owns or 

controls a legal entity. Determining beneficial ownership requires that ownership 

be traced back through all intermediate corporate owners, until ownership is 

determined to reside in either an individual or a publicly traded company.”

Those Guidelines require the identification and screening of all Beneficial Owners holding, 

directly or indirectly, five percent or more of the IDB Invest Counterparty. If the IDB Invest 

Counterparty or a Beneficial Owner of the IDB Invest Counterparty is publicly traded, the names 

of those owners of the publicly traded company holding a ten percent or greater interest in the 

publicly traded company are identified and screened.

IDB Invest screens the ultimate beneficial owners of proposed counterparties through relevant

databases to identify integrity risk indicators. These include being considered a politically 

exposed person, being subject to economic or administrative sanctions, or being under criminal 

investigation or involved in administrative or civil proceedings that allege serious ethical or 

financial misconduct. Failure to provide information on beneficial owners disqualifies a 

company from receiving funding from IDB Invest (although there is an exception under the 

guidelines for clear mitigating circumstances, IDB Invest in practice has never granted an 

exception). IDB Invest also posts project descriptions on its website, which may include the 

names of sponsors and major shareholders in the company, including some beneficial ownership 

information.

The Integrity Due Diligence relevant to beneficial ownership may also include additional

elements. Such additional elements could include: (i) if a company or its controlling 

shareholders use cross-border corporate structures, IDB Invest may conduct “structural due

diligence”, which includes assessment of certain tax-related risks (e.g., risks presented by the use 

of offshore financial centers); and (ii) if the company is a fund, IDB Invest also conducts IDD on 

the general partner/fund manager—even if the general partner does not meet the five percent 

ownership threshold—and the general partner/fund manager’s direct and indirect owners to the 

five percent level.
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The Office of the U.S. Executive Director for the IDB and IDB Invest continues to advance 

United States policy in this area and consistently presses for integrity, high due diligence 

standards and information disclosure in all projects.

Conclusion

In the past fiscal year, the MDBs have made progress in advancing efforts to increase 

transparency and to ensure the integrity of their institutions through the collection and analysis of 

beneficial ownership information. As outlined in this report, the United States strongly 

encourages and supports these efforts. Through obtaining this information, the MDBs augment

their ability to screen and monitor the recipients of MDB financing. In the process, the MDBs 

lead by example and encourage greater integrity, due diligence, and accountability in other 

international financial institutions. The Treasury Department and the respective Offices of the 

U.S. Executive Director in each MDB will continue to encourage the MDBs to collect and verify 

pertinent information about beneficial ownership.