As a part of the Sanctions and Anti-Money Laundering Act 2018 Overseas Territories were required to introduce public registers of beneficial ownership within two years. The previous Government then extended the deadline to implement registers by the end of 2023. Beneficial ownership refers to the person who ultimately owns or controls an asset and registers aim to provide transparency and to fight against corruption, tax evasion, and money laundering. The UK introduced its own public register in 2016.
The Crown Dependencies (Guernsey, Jersey, and the Isle of Man) are not part of the UK and the UK does not legislate for them without the consent of local governments. In the case of fourteen UK Overseas Territories Parliamentary legislation is rare, however, the UK Parliament is constitutionally supreme and there are no limits on its ability to legislate for them.
Since 2017 the Crown Dependences and the six Overseas Territories with significant financial services sectors (Anguilla, Bermuda, British Virgin Islands, Cayman Islands, Gibraltar, and the Turks and Caicos Islands) have operated an “exchange of notes” arrangements with the UK whereby they provide law enforcement agencies with company beneficial ownership information on request. The Home Office has said that the agreement is “extremely useful”.
All of the Overseas Territories have committed to introducing publicly accessible registers and several already have private registers in place e.g. Bermuda, British Virgin Islands, Cayman Islands, and the Turks and Caicos Islands. However, only Gibraltar and Montserrat have implemented a public register of beneficial ownership with Saint Helena following in July 2025. The Crown Dependencies committed to introducing public registers in 2019 but following a 2022 European Court of Justice ruling they have taken a differing legal view on implementing publicly accessible registers.
The November 2024 UK and Overseas Joint Ministerial Council communiqué made commitments to “improving our corporate transparency by implementing Accessible Registers of Beneficial Ownership, with some territories implementing registers with legitimate interest access and others implementing Publicly Accessible Registers of Beneficial Ownership (PARBOs”). The communiqué said that it was the UK Government’s ambition that “PARBOs become a global norm and its expectation that Overseas Territories and Crown Dependencies implement full PARBOs”.
I will closely track the progress of the implementation of PARBOs and question Ministers at regular intervals about progress.
