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 Consolidated Appropriations Act, 2021

United States Department of the Treasury

April 2022
1 

Report on Beneficial Ownership Information Practices at the

Multilateral Development Banks

 

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 

Consolidated Appropriations Act, 2021, P.L. 116-260. This report provides an update on the 

policies and practices that the MDBs have implemented in FY2020 through June 2021 to 

enhance disclosure of beneficial ownership information in their respective institutional 

operations1

. 

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 2020 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.

2

 

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

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

Development Association (IDA)

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

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

fiscal years 2018 through 20213

 and publishes beneficial ownership data for the winning bidders 

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

Review Committee, which reviews the highest risk and value procurement) financed by World 

1 This report includes the reforms the International Financial Institutions took and U.S. engagement on this issue 

during FY20 and through June 2021. This report is also adding the North American Development Bank this year. 2 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

3 The World Bank’s fiscal year runs from July 1-June 30.
2 

Bank projects. These procurements are expected to represent approximately up to 40 percent of 

all World Bank-financed procurements by value. 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. World Bank Management reviews and reports to the Board of Directors 

on implementation progress, including any lessons learned. The next report will be presented in 

mid-2022. 

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, in United Nations Development Business (UNDB, 

https://devbusiness.un.org/), the World Bank’s external website (www.worldbank.org) and on 

the World Bank Procurement App. 

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

projects approved after November 1, 2017. As of June 30, 2021, beneficial ownership 

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

approximately $1.88 billion. The pilot covers around 37 planned ongoing procurements 

estimated at $4 billion. 

The World Bank conducts 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. To date, the World Bank indicates that the response to the pilot continues to be 

positive and that to date, they did not identify any particular issue or unintended consequences in 

the procurement process that triggered any red flags warranting further due diligence. 

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. 

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 five percent or more of an entity, including indirect and ultimate 

beneficial owners, as well as the top five direct owners as applicable. If the entity is a fund, IFC 
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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 lists4. 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. IFC has also recently 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 U.S. 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. Considering IFC’s operational environment, notably that it conducts operations 

with private sector companies, there are certain privacy, access to information and confidentiality 

restrictions in Board-approved policies and legal contracts limiting IFC’s ability to disclose 

beneficial ownership information. 

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 

4 These enforcement lists include UN Security Council Sanctions list, plus other international recognized 

sanctions, regulatory and enforcement lists (including EU restrictive measures, OFAC, UK sanctions), 

plus its debarment and MDB cross debarment lists.
4

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. The EBRD has maintained its integrity 

standards through the pandemic and in its emergency lending, including by implementing 

resilience programs to ensure checks around Know Your Customer (KYC) and beneficial 

ownership are not compromised. Like the other MDBs operating in the private sector, the EBRD 

conducts risk-based IDD on the companies in which it invests. The EBRD will not proceed with 

a transaction without knowing who the beneficial owners are. 

As the first step in the IDD process, the EBRD identifies all the beneficial owners in projects 

under consideration (other than where a very large number of small shareholders makes this 

impractical for those with de minimis holdings, or where a listed company’s ownership is 

identified as being very fluid) and provides such information in financing proposals. All staff 

involved in EBRD projects undergo in-person training on the guidelines. EBRD staff are 

responsible for collecting and vetting beneficial ownership information based on information and 

documentation gathered through site visits, discussions with the client, and general knowledge of 

the region/sector, as well as Business Information Services (BIS) searches. The Domiciliation 

Unit within the EBRD Office of the Chief Compliance Officer has, in projects involving offshore 

ownership structures, further facilitated and enhanced the review of beneficial ownership. 

EBRD investments that involve politically exposed persons, complex ownership structures, 

clients with poor past business practices, or other high-risk clients will trigger enhanced IDD. In 

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

The EBRD publishes information on its project partners in accordance with the Bank’s Access to 

Information Policy (AIP) and Project Summary Documents (PSDs). The EBRD publishes 

beneficial ownership information where practicable. 

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. The EBRD has organized donor-sponsored 

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

important understanding of the concept of beneficial ownership. 

The Office of the U.S. Executive Director continues to engage with the EBRD in the review of 

individual operations and has raised objections, for example in June 2021, in an EBRD 
5

investment in the Sophia airport development project in Bulgaria which involved a U.S. 

Specially Designated National. The Office of the U.S. Executive Director will continue to 

monitor progress on expanding transparency in the use of EBRD funds. 

African Development Bank

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

AfDB continues to implement its revised procurement policy (updated in 2015), which improves 

its approach to collecting and publishing beneficial ownership information in the procurement 

process for sovereign operations. The new AfDB Operations Procurement Manual (published in 

2018), which is publicly available, implements the 2015 policy and 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. 

The Operations Procurement Manual and the accompanying guidance note (published on the 

Bank’s website) 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 for an AfDB-financed sovereign contract above a specified monetary 

threshold disclose publicly its beneficial owners. The applicable thresholds are set down for the 

relevant Bank-financed transaction based on country conditions identified in the applicable 

Bank’s Procurement Assessment Report (BPAR) as well as the FATF country-level assessment. 

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 entity. This requirement and a form to be 

completed by the winning bidder have been included in the latest version of the Bank’s Standard 

Bidding Documents, which are published on the Bank’s website and are currently being used by 

Borrowers. The collected information will then be 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 AfDB continues to enhance its screening capacity of beneficial ownership information of 

clients with the procurement of additional due diligence tools. A Bank wide Master Screening 

tool will be launched later this year that will be accessible to all Bank Staff for both ad hoc and 

automated screening of clients’ information, including shareholders and ultimately the 

information of beneficial owners.

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 
6

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, as noted above. 

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 

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 and is looking forward to 

reviewing the evaluation of the World Bank’s pilot to understand lessons learned.

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 of the U.S. Executive Director has urged AsDB to include 

ownership structures and beneficial ownership information in individual proposals that are 

published to the AsDB website and to balance the desire of some clients for confidentiality 

agreements against principles of openness and transparency. 

Inter-American Development Bank

Procurement arrangements for the Inter-American Development Bank’s (IDB) sovereign 

operations 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 
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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). The information 

published on its website includes the name of the firm, its location, and the value of the contract. 

 

IDB procurement policies that took effect in 2020 establish that executing agencies in 

international competitive bidding processes may request beneficial ownership information from 

the company that will be recommended for award before the publication of the award of the 

contract. Per these policies, the information that would 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 (https://devbusiness.un.org/) and 

will be forwarded for publication on the website of the IDB. 

IDB Invest

 

The Inter-American Investment Corporation (IDB Invest) is the private sector arm of the IDB. It 

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

countries. IDB Invest’s integrity due diligence (IDD) guidelines require the identification and 

screening of all beneficial owners holding, directly or indirectly, five percent or more of the 

counterparty. If the counterparty or a beneficial owner of the counterparty is publicly traded, 

then those owners who hold a ten percent or greater interest in the publicly traded company are 

also identified and screened.

IDB Invest screens using relevant databases to identify integrity risks. These include being: (i) 

considered a politically exposed person; (ii) subject to economic or administrative sanctions; (iii) 

under criminal investigation; or (iv) 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. On its public website, IDB Invest posts project 

descriptions that may include the names of sponsors and major shareholders in the relevant 

company as well as beneficial ownership information. 

 

The IDD relevant to beneficial ownership may also analyze whether a company or its controlling 

shareholders use cross-border corporate structures, an exercise that often includes assessments of 

certain tax-related risks (e.g., use of offshore financial centers). Additionally, if a fund is 

receiving the loan, IDB Invest conducts IDD on the general partner/fund manager—even if the 

general partner does not meet the five percent ownership threshold—and in some cases, on the 

general partner/fund manager’s direct and indirect owners.

 

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, as well as the presumption of maximum 

disclosure and transparency in all IDB Group policies. 

North American Development Bank 
8

The North American Development Bank (“NADBank”) is a binational regional development 

bank headquartered in San Antonio, TX. It was established together with its sister institution the 

Border Environment Cooperation Commission (BECC) in 1994 under the former North 

American Free Trade Agreement (NAFTA). NADBank and BECC merged into a single 

institution in 2017. The United States and Mexican governments capitalize the NADBank in 

equal part and share equal representation on the Board of Directors. NADBank provides grants, 

loans, and technical assistance for environmental infrastructure in the U.S.-Mexico border 

region. It prioritizes projects in the water, solid waste management, air quality, energy, and basic 

urban infrastructure sectors. 

Consistent with its Money Laundering Prevention and Know Your Client policy, NADBank

gathers information from project sponsors, additional sources of funding, and major contractors 

and parties directly involved with a project seeking NADBank funding. NADBank also gathers 

information on parties owning 25% or more of such entities. NADBank collects information on 

the ownership structure and key controllers during its initial due diligence phase and seeks 

updates to this information prior to annual disbursements and after any changes to the ownership 

structure. NADBank validates this information through various documents depending on the 

structure, including incorporation documents, public filings and, in the case of public projects, 

government decrees.

For every project it considers for approval, NADBank publishes on its webpage a certification 

and financing proposal that summarizes all relevant project information, including the name of 

the project sponsor and of any special purpose corporation that may be involved in project 

implementation. The Board of Directors receives the full document which includes the 

environmental and technical feasibility of the project, the loan amount, and a general overview of 

the financial criteria evaluated. This document does not include any details regarding the 

corporate structure or ultimate beneficial ownership of a project. This is an area that Treasury 

will engage with NADBank management to provide for more transparency on ultimate beneficial 

ownership structures.

Conclusion

The MDBs continue to improve their transparency and accountability in their institutions through 

the collection and analysis of beneficial ownership information. Through obtaining and 

presenting this information for projects and on specific websites, the MDBs proceed to make 

progress in augmenting 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.