Beneficial Ownership title

The Land Registry privatisation public consultation notes that 13% of land and property title is not registered and that could undermine lowest cost identity verification due diligence, credit scores and increase non-compliance rates to maintain the People with Significant Control register.

The Land Registry privatisation debate could progress open data and risk management with total registration and purchase options and — I am not familiar with the dataset — perhaps price first advertised by each agent, unique landlord reference and compulsory purchase reference.

Anyway, one response to the public consultation, prompted by the Open Data Camp in Bristol:




Interim Unilateral Beneficial Ownership Option

Could an interim unilateral beneficial ownership option accelerate #anticorruption summit aspirations?

The beneficial ownership debate is about lobbying and policy statements and legislation and registers and incorporation systems.  By the end of the year, jurisdictions could have a public register or a private register or no progress on a register.

On 4th April 2016 OpenCorporates announced a Global Beneficial Ownership Register project with more context in a blog post from the Open Contracting Partnership and the ONE campaign policy director.

I have already established a proof of concept on declaration of beneficial ownership on a public register, it required an internal legal opinion from Her Majesty’s Attorney General chambers because deeds on a public register were assumed to be between two parties and that a declaration of beneficial ownership by definition only included one party:

Of course, ideally, the Isle of Man Deeds Registry would be online with public blockchain technology.

Does anyone actually have a register classification scheme to reference?  GOBR will support self-reporting to bypass any delays in specific jurisdictions or specific corporate entities (business names, charities, foundations, trusts) but a draft scheme would be helpful to prompt discussions.  For example:

Level Classification Notes
0 unregulated agents nothing on client file
1 regulated agents legal requirement to hold beneficial ownership details
11 Private 1 star reference to centralised corporate register to contact declared officers or the regulated agent
12 Private 2 stars reference to centralised corporate register to contact officers or the regulated agent

legal power to require beneficial ownership declaration by officers or disclosure by the regulated agent (without tipping off clients)

13 Private 3 stars centralised beneficial ownership register with meta data to decentralised beneficial ownership data (similar to

legal requirement to update contemporaneously

14 Private 4 stars centralised beneficial ownership register
15 Private 5 stars centralised beneficial ownership register

a Service Level Agreement (for example, 24 hours) or perhaps cross-border law enforcement  logins with specific user audit trail and unique case references

15 Private 5 stars centralised beneficial ownership meta data register to decentralised beneficial ownership data (similar to
16 Private 6 stars decentralised beneficial ownership register
17 Private 7 stars decentralised consolidated corporate register with beneficial ownership data (i.e. government only private blockchain to support tax information exchange agreements)
21 Public 1 star centralised corporate register with optional beneficial ownership declaration (i.e. self-reporting)
22 Public 2 star centralised beneficial ownership register
23 Public 3 star centralised beneficial ownership register

aggregated analytics on public interest trends

24 Public 4 star centralised beneficial ownership register

open data API to support projects such as GBOR

24 Public 4 star centralised beneficial ownership meta data register to decentralised beneficial ownership data (similar to
25 Public 5 stars centralised beneficial ownership register

open data API to support projects such as GBOR

legal requirement to update contemporaneously

25 Public 5 stars centralised beneficial ownership meta data register to decentralised beneficial ownership data (similar to

legal requirement to update contemporaneously with randomised regulator audits

26 Public 6 stars decentralised consolidated corporate register with beneficial ownership data i.e. public blockchain operated by governments, the media, stock exchanges, universities, charities, etc.
27 Public 7 stars decentralised consolidated corporate register with beneficial ownership data i.e. public blockchain operated by governments, the media, stock exchanges, universities, charities, etc.

legal requirement to update contemporaneously

I have relentlessly encouraged the Isle of Man to progress in the annual Open Knowledge open government league table from top 100 (rebased) to top 40 to top 20 and hopefully top 10 in Q3 2016.

On 6th May 2016 the Isle of Man Government announced new functionality with an online incorporation and demonstrates that new functionality is an option.  An important factor though is that smaller governments typically outsource the incorporation system and therefore any new functionality requires a prioritised business case in an increasingly complex (i.e. slower) cross-government procurement process or approval of an unplanned external cost (i.e. higher) prompted by global macro factors as either an upgrade by the existing supplier at backloaded commercial rates or a securitisation option that would increase fees that may not then be internationally competitive.

What do I mean by an interim unilateral system?

Something that would address reasonable concerns on competitor jurisdictions.

Consider a legal requirement that a specific beneficial owner must:

  • adopt a unique anonymised beneficial owner reference (similar to the global legal entity identifier) in a specific jurisdiction
  • consistently apply that unique beneficial owner reference to any corporate activity in a specific jurisdiction
  • declare that a unique beneficial owner reference has been applied on key documents such as incorporations, annual returns, share allotments and share transfers.

The largest impact is likely to be when agents discover they do not actually have an “exclusive” relationship with a beneficial owner (i.e. they lied) and technically they are not eligible for discounted management fees on corporate structures.

Unilateral actions could prompt a multilateral network effect.

Feedback welcome.

Funding offers welcome too!



Anti-Corruption Summit in London

11th May 2016:  updated to include nominal cost draft UK #anticorruption guarantee scheme forwarded to Open Knowledge session lead Mor Rubenstein and highlighted via Twitter (I guess the next blog post should be insights on the real world path to beneficial ownership public registers):

a draft UK #anticorruption guarantee scheme

Governments typically take a long time to progress anything meaningful and individuals rarely have the self-funding to sustain significant efforts year on year and civil society funding mechanisms are largely undeveloped or very conservative in the sub-national jurisdictions likely to be discussed the most.

Undoubtedly, some non-standard open government experts and open data hacktivists could add a lot to the pubic and private discussions at the Anti-Corruption Summit in London next week.  Unfortunately, they are the ones least able to add a lot to an offshore bank account or a credit card lol:

Screenshot 2016-05-07 at 15.15.48

I have helped push an offshore jurisdiction in the Open Knowledge open government league table from top 100 (rebased) to top 40 to top 20 and potentially to top 10 in Q3 2016 but nonetheless I very reluctantly had to ask several times not to be nominated in the recent Open Government Partnership International Expert Panel round precisely because of the unsustainable commitments requested of anyone in the open data community determined to self-fund via debt if required rather than risk independence given the requirements to travel potentially to the other side of the world, the implied requirements stop paid work to progress unpaid work, etc.

Fix the open data funding mechanisms and fix everything faster.

In the meantime, I have milestones and deep insights on bitcoin and blockchain and the Isle of Man gambling regulator is expected to legalise bitcoin transactions in July 2016 so I would welcome an open data CSR fellowship, an advisory board role or project specific consultancy!


Incorporations in Google Maps

Google Maps front end to OpenCorporates

The open data community often talks about how open government programmes let volunteer developers and civil society funded projects help end users such as citizens, taxpayers and voters but the largest end users of open data are typically governments, financial services companies, international charities and even gambling companies.

Chris Taggart was a speaker at a British Computer Society Isle of Man open data unconference in early 2011.

I originally configured a map in late 2011 to help less digital end users at the Isle of Man Government in Income Tax, economic development, foreign aid and regulators leverage other government open data as an opportunity to demonstrate value and to build momentum on an open government programme.  It helped visualise incorporations to non-technical end users and helped end users without English to access the data:


Corporate Register: Isle of Man

With previous expertise as a legal compliance officer in an offshore companies registry and as a group IT manager in global wealth managers and, prompted by email threads with Chris Taggart, James McKinney and others, I realised that Incorporations League Tables could visualise expertise by SIC code and year on year market share trends but it also surfaced issues such as free text registered office addresses, free text officer names, aged shelf companies, excessive directorships and client dumping in SAR frameworks:

Incorporations League Table

Incorporations League Table: Isle of Man

I recently noted 31 extra jurisdictions since early 2015 and updated the map:

  • Australia
  • Bahamas
  • Belgium
  • Canada: New Brunswick
  • Canada: Newfoundland and Labrador
  • Cyprus
  • Hong Kong
  • Latvia
  • Myanmar
  • Tajikistan
  • Uganda
  • USA: Alabama
  • USA: Arkansas
  • USA: Colorado
  • USA: Delaware
  • USA: Hawaii
  • USA: Indiana
  • USA: Kansas
  • USA: Kentucky
  • USA: Minnesota
  • USA: Nebraska
  • USA: Nevada
  • USA: New Hampshire
  • USA: New York
  • USA: North Carolina
  • USA: North Dakota
  • USA: South Carolina
  • USA: Utah
  • USA: Virginia
  • USA: Wisconsin
  • Viet Nam

Is there a prioritised list of extra jurisdictions and is it reshaped by events such as #PanamaPapers or just limited by volunteer efforts?


Style of Open Government

A response to an #opendata movement exchange between Tom Steinberg (founder MySociety UK) and John Wonderlich (director Sunlight Foundation USA) about the importance of outrage from someone that struggles to push and to collaborate on open government at the same time in parliament, in government and in large corporates:


It has taken 10+ years effort to earn the trust to successfully identify and cajole the *right* career civil servants and the *right* politicians to go to an open data bootcamp.

The efforts are certainly built on outrage.

I believe I am the only person in the Isle of Man to go to court over the code of practice on access to information with the Companies Registry and one of the reasons I ended up helping Chris Taggart at opencorporates to webscrape Liechtenstein, Gibraltar, Cyprus, etc.  In a small and, more importantly, offshore jurisdiction that is usually very career defining (a.k.a. limited to the private sector).  That is outrage.

I have allocated 80% annual leave for years and “volunteer” for anything that earns time in lieu (no paid overtime anyway) to attend TransparencyCamp in Washington DC for the masterclasses or RISE in Hong Kong to help push harder on #blockchain.  I have explored how to help get cash directly into the hands of beneficiaries with the bitcoin XBT currency code in the global aid flow database and then just did it because no-one else would in my timescale.  That is outrage.

I have been on that cold train station platform late on a Sunday at the end of an exciting but draining unconference when a career civil servant  says they are looking forward to the next 2 days time in lieu to recover and you have to go to the day job.  That is outrage.

Yes, the funding mechanisms are broken and the Open Contracting Data Standard will probably not help fast enough to help the early stage open data generation.  I have made some difficult decisions already in 2016.  I have had 2 direct debits bounce and my credit reference is impacted.  That is outrage.

I was at the Open Knowledge bootcamps in London, Warsaw, Helsinki, Geneva and Berlin but increasingly only the handfuls that ended up with some government funding were still able to afford or to justify self-funding from other consultancy.  Tech startups know or eventually learn that fundraising is increasingly a full-time role and only successful if you have a CTO co-founder to help the fundraising.  The rightest and brightest ideas needlessly slip through the fingers of society every month and I am powerless to stop it.  That is outrage.

Just last night, I hosted a parliament session with a small group of 16+ year olds in care to debate a motion for the government to substantially fund driving lessons as they do not have parents to subsidise or to practice driving at weekends.  A quiet girl had exhaustively researched driving lesson costs (average GBP 28 per hour) and average lessons (47) and costs.  A young mother with a baby had powerful points and the director of childrens services agreed in principle to amend the department policy.  I was humbled.  I recognise channelled outrage.

I have made the right decision.  Collaboration and hacktivist.  Open data, when do we want it, now! ;O)


bitcoin milestones: XBT


I’ve blogged before about the pipeline of pending bitcoin milestones and country growth hacking so I should highlight progress on XBT as a currency code.

I attended the open data summit in Ottawa in May 2015 and prompted by some hardcore Q&A I decided to unblock the stalemate on BTC as a currency code.

I discovered that the United Nations and World Bank supported global aid flow database already includes a mechanism to include politically sensitive currency codes.  X is used as a prefix to the established currency code BTC and truncated to 3 characters, i.e. XBT.

A draft strategy emerged in the corridors at a fringe unconference on Saturday and fermented at a micro brewery in Gatineau (Quebec) on Saturday night:

  • shortlist charities already accepting bitcoin donations
  • register a wallet with a bitcoin operator based in the same country as the charity
  • process a cross-border bitcoin transaction
  • handcode the bitcoin transaction as cross-border aid flow in an XML aid flow transaction file to include XBT as the currency code
  • leverage an Isle of Man login to the global aid flow database to upload the cross border aid flow transaction file — ok, the system was developed to process millions of dollars/pounds/swiss francs/etc but millibits sounds like millions
  • request that the IATI technical support team add an XBT currency code to the official code list to stop validation errors in thousands of aid flow management systems and apps linked to the IATI API

With due diligence on shortlisted charities and previous bitcoin transactions via Blockchain Luxembourg, firstly I selected a German charity Amani Kinderdorf with projects in Africa to support AIDS orphans and secondly I selected a German bitcoin wallet operator cubits based on personal recommendations.

Disclosure: I subsequently accepted an advisory board member role for 3 months to research bitcoin mass adoption.

On 5th June 2015 I uploaded the transaction file.

On 11th September 2015 IATI started a private consultation on XBT as a currency code within the IATI Technical Advisory Group.

Disclosure: I am a member of the IATI TAG.

On 1st October 2015 it was confirmed that XBT had been added as a currency code to the IATI global aid flow database system emdorsed and supported by the United Nations, the World Bank, etc.

So what?

I have accumulated extensive relevant expertise via 2 years on the Bank of England currency tracking system, the Open Bank Project (the first batch at Level39), a 1 year open banking placement at the Treasury in the Isle of Man Government and bitcoin milestones, so I have had some interesting discussions on possibilities with potential partners in Dublin, Zurich, Luxembourg, New York, Melbourne, etc.

Obviously I have followed the Barclays project with Safello and they are expected to support bitcoin charity donations in Q4 2015 or Q1 2016.

Disclosure: I applied to the Barclays Techstars fintech accelerator.

I had previously discussed a large opportunity in wealth management with Cayman National Bank and, prompted by the announcement of the HM Treasury Open Banking Working Group chaired by Barclays and the Open Data Institute, more recently with Barclays Isle of Man.  Cayman National Bank didn’t have the right existing client profile but I think Barclays will need to do the London thing before it has enough internal momentum to progress something more ambitious offshore.

I defined and requested that Jersey, Guernsey and Gibraltar corporate register and charity regulator reference codes should be added to the global aid flow database system.  Jersey and Guernsey have been added but Gibraltar does not presently meet all the technical requirements.

On 10th November 2015, I flagged a hidden issue at an excellent Wragge Lawrence Graham fintech event with a great keynote by Bob Ferguson from the FCA and “ask me anything” fintech VC panel — actually lots of fintech milestones are self-funded so a mechanism to fund or to refund hacktivist research could accelerate progress in any jurisdiction.

The regulatory sandbox at the UK FCA with a government umbrella company and representative appointment risk management mechanism is real world help to support fintech startups and to let large operators dip their toes in the water and even fail small.

On 1st June 2015, in the UK, the International Development (Official Development Assistance Target) Act 2015 means that 0.7% of spending will be allocated to aid flow each year so transparency on budgets such as £11.4 billion in 2014 are increasingly important.

A little reported response to the Paris attacks was to increase aid flow to fragile states from 30% to at least 50% — the jurisdictions at highest risk of diversion.  So the need to maximise financial reporting at lowest cost, the need to visualise soft power dynamics and ultimately the need to demonstrate sustainable social impact will support a shift to blockchain technology, daily micropayments direct beneficiaries and perhaps even a BIP to automatically allocate some bitcoin ecosystem processing to the nearest direct beneficiary mobile phone as an income stream.

At the RISE conference in Hong Kong I arranged to follow up on key points with Bobby Lee.  Downstairs at the Facebook developers bootcamp I noted that Facebook had hired talent from Ripple etc and that, for example, mainstream bitcoin apps would be ok.

On 18th November 2015, Facebook launched the non-profit donations option but I would expect the most progressive social impact via the initiative.

Next week, I will progress a bitcoin milestone in London that should indirectly progress Banknotey, a platform to finally extend ebusiness to cash customers so they can have a better life too.

Best regards,

Graeme Jones

bitcoin policy advisor (Isle of Man)

open government hacktivist (global)

co-founder, Banknotey Technology Limited (UK)


Nepal, interim data and IATI engagement


Prompted by the news coverage of Nepal, the IATI TAG unconference in Ottawa next week and an open data superhero like Bibhusan Bista, I thought I would look at the world class UK Government open data and the level of IATI engagement.

I assumed that IATI would become the natural hub to share real time open data and to help map official requests and responses to an unfolding crisis such as the Nepal earthquake.

Matched donations are a very successful policy but most donors still like to click through to see the matched donations, data visualisations on allocation efficiency and inspirational images and video clips to see the positive impact of donations.

So interim data should be an IATI focus.


I read the latest news on the UK Government Department for International Development dated 20 May 2015:

Nepal earthquake: UK aid response

The UK’s humanitarian response now stands at more than £33 million and includes:

£10 million to rebuild vital health services in the worst affected districts;

£5.3 million for UN agencies in Nepal to coordinate the international relief effort and provide clean water and shelter for affected families;

£3 million released under the Rapid Response Facility (RRF) to six charities and NGOs already working on the ground: Save the Children, Mercy Corps Scotland, Care International UK, ActionAid, Oxfam and Handicap International;

£2 million for the British Red Cross;

£5 million to match public donations to the Disasters Emergency Committee’s appeal, which will support NGOs on the ground;

a £5 million package to provide a further team of 30 trauma medics, logistical support and equipment to ease congestion at Kathmandu Airport and humanitarian experts in water, health and sanitation. DFID also deployed a team of more than 60 UK International Search and Rescue (UKISAR) responders and specialist rescue dogs;

£2.5 million for the UN Humanitarian Air Service to enable organisations already on the ground to deliver aid to isolated areas; and

more than £300,000 for Mission Aviation Fellowship (MAF) to provide two Airbus 350 helicopters to get help to more remote regions

I noted that the updated infographic by Ricci Coughlan/DFID has had 4880 views.

I looked at the UK Government DfID publisher page on the IATI website — 127 files but strangely only 1 follower for a leading national publisher:

I looked at the specific file on Nepal but strangely 0 followers:

DFID Activity File Nepal

I downloaded the dataset (all transactions in CSV format):

I reviewed the 2560 rows, focused on column Q (transaction-value_value-date) and sorted the dataset into ascending date order.  I filtered the dataset to rows dated 2015.  The dataset includes 1 commitment in 2015 Q1, 1 commitment in 2015 Q3 and the 2015 Q1 transactions.

I then sorted the dataset on column V (receiver-org).  The dataset includes 3 rows with aggregated small transactions in 2014 Q4 (deleted), 2 rows with commitments (deleted), 1 row with negative expenditure such as an overpayment (deleted), 12 rows marked “correction” with a transaction and reverse transaction (deleted) and 37 rows perhaps unexpectedly marked “supplier name withheld” in a transparency database (retained).

total transactions value = GBP 8,609,560


I downloaded the Open Nepal dataset on commitments and aid flow and filtered UK transactions:

total transactions value = GBP 32,862,438

19x rows

I then downloaded and filtered the source dataset at the UN OCHA FTS (Financial Tracking Service) on the Nepal appeal site:

total transaction value = GBP 33,897,941

19x rows but with an extra GBP 295,858 to UN Agencies (GBP 739,645) and an extra GBP 739,645 to UNICEF National Committee/UK (GBP 2,218,935)

However, the IATI dataset is significantly lower due to quarter end reporting.

total transactions value = GBP 8,609,560


Our hugely successful Aid Match scheme has helped boost the British public’s own generous donations to different charity campaigns.

A good enough reason to upload interim data is so that private donors can click through to matched government donations and any third party data visualisations, infographics, etc.


So could interim data increase IATI engagement?  Could twitter change the world??

#UKaid #Nepal


obviously Chair John Adams




DFID welcomes new ministerial team

re-appointment as Minister of State for International Development, Desmond Swayne


appointment as Minister of State for International Development, Grant Shapps


re-appointment as Secretary of State for International Development, Justine Greening


appointment as Parliamentary Under Secretary of State Baroness Verma

@Baroness_Verma (only 1 tweet though)