SIGIL SARL — Buea, Cameroon
FATF Recommendation 24: what registries must deliver
What FATF Recommendation 24 is
FATF Recommendation 24 is the international standard on the transparency and beneficial ownership of legal persons. It is one of the forty Recommendations maintained by the Financial Action Task Force (FATF), the intergovernmental body that sets the global standards against money laundering and terrorist financing. Its purpose is to make one question answerable everywhere: which natural persons ultimately own or control a legal person — the beneficial owners — and can the authorities find out quickly enough for the answer to matter.
The Recommendation’s core sentence has a precise shape. Countries should ensure that adequate, accurate and up-to-date information on the beneficial ownership and control of legal persons can be obtained or accessed rapidly and efficiently by competent authorities — the wording of the revised Recommendation itself. Since March 2022, each of those adjectives carries a definition a system can be measured against.
Recommendation 24 is addressed to countries, not to software. But a country discharges it through machinery: the register that holds declarations, the pipeline that verifies them, the channels through which authorities query them. This page reads the Recommendation as a set of system requirements — jurisdiction-generic, because they are derived from the standard itself rather than from any one country’s transposition of it.
The March 2022 strengthening
At its Plenary of 2–4 March 2022, the FATF adopted amendments to Recommendation 24 and its Interpretive Note, significantly tightening the beneficial-ownership standard. The direction of the change is unmistakable: away from principle, toward mechanism.
The centrepiece is the multi-pronged approach to collecting beneficial-ownership information. Companies must obtain and hold their own beneficial-ownership information; the information must also be held by a public authority or body functioning as a beneficial-ownership registry, or through an alternative mechanism that likewise enables rapid and efficient access; and countries combine these with other existing sources of information. The FATF’s own evaluations supplied the reasoning: countries drawing on several sources proved more effective at preventing the misuse of legal persons than countries relying on any single one.
The information standard itself was sharpened. Where the earlier text asked for information that was adequate, accurate and timely, the revised standard asks for information that is adequate, accurate and up to date — and relocates timeliness into the access requirement: obtained or accessed rapidly and efficiently. The same amendments prohibited the issuance of new bearer shares and bearer-share warrants and required existing ones to be converted or immobilised, strengthened the transparency obligations around nominee shareholders and directors, and required public authorities to have access to beneficial-ownership information in the course of public procurement.
In March 2023 the FATF published its updated Guidance on Beneficial Ownership of Legal Persons to help countries implement the revised Recommendation. The definitions below are drawn from it.
From legal text to system requirements
None of this is self-executing. Each obligation in the Recommendation resolves, in practice, into a property a registry system either has or lacks. The table below states that mapping in jurisdiction-generic terms — it holds for a beneficial-ownership register anywhere, because it follows from the standard rather than from any local statute.
| Recommendation 24 asks for | The system must provide |
|---|---|
| Adequate information | A data model that resolves to natural persons and captures the means and mechanisms of ownership and control — not only names and percentages |
| Accurate information | Verification machinery that checks declarations against reliable, independently sourced data, and records its evidence |
| Up-to-date information | Update obligations enforced in software: change-triggered filings, periodic confirmation, and re-screening against sources that move |
| Rapid and efficient access | Structured, queryable records reachable by competent authorities through defined channels — with every access itself logged |
| A registry or alternative mechanism | An operating institution, an availability discipline, and an open export format that keeps the data portable |
“Adequate”: what it demands of a data model
The FATF’s 2023 guidance defines adequate information as information sufficient to identify the natural persons who are the beneficial owners, and the means and mechanisms through which they exercise ownership or control. Both halves bind. A register that stores names but not mechanisms fails the second half: a percentage alone does not explain a company controlled through a shareholders’ agreement, a family arrangement, or a chain of intermediate entities.
For a data model, this means every record must resolve through any chain of entities to natural persons; interests must be typed — equity, voting rights, appointment powers, contractual control, nominee arrangements with the person behind the nominee identified; the legal basis of control must be recordable where ownership alone does not explain it; and numeric precision must keep thresholds meaningful, because a register that cannot distinguish 24.9 from 25.0 per cent cannot apply a 25 per cent rule. Adequacy is decided at schema-design time. No later verification stage can recover a fact the schema never asked for.
“Accurate”: what it demands of verification machinery
Accurate information, in the guidance’s terms, is information verified against reliable, independently sourced documents, data or information — with the degree of verification allowed to follow risk. The operative word is independently: a register that only stores what declarants assert is a filing cabinet, not a source of accurate information.
That implies machinery. Identity checks against authoritative civil sources, so a declaration cannot rest on an invented person. Screening against sanctions and politically-exposed-person lists, with match quality quantified rather than asserted. Cross-source comparison, so that two official sources disagreeing about one entity raises a flag by itself. And — the discipline that separates serious systems from hopeful ones — an explicit representation of uncertainty. A pipeline that cannot say “insufficient evidence” will convert silence into a clean result, and the register will look most accurate precisely where it knows least.
Accuracy must also survive review. Every verification outcome needs recorded evidence — which source, which match, what confidence — so that a human reviewer, a supervisor, or an assessor can reconstruct why the register believed what it published.
“Up to date”: update obligations and refresh discipline
Up-to-date information, per the guidance, is information that is current and updated within a reasonable period after any change — the FATF offers one month as an example of such a period. This is a requirement about obligations and about clocks: someone must be obliged to report the change, and the system must make that obligation cheap to honour and visible to ignore.
In system terms: change-triggered filings with the reporting clock exposed to the declarant and the operator alike; periodic confirmation, so that an entity whose ownership never changes still re-affirms it on schedule; and staleness made legible — a record not confirmed within its period should say so on its face, not present itself as current.
There is a second clock the standard implies rather than states. The sources a register verifies against — sanctions designations, politically-exposed-person status, adverse findings — move on their own. A declaration verified in January can be contradicted by a designation in March. Up to date therefore also means re-screening published records against refreshed sources on a defined cycle, and refusing to conclude from list data the system knows to be stale.
Access for competent authorities — and the audit trail
The revised Recommendation requires that competent authorities obtain or access the information rapidly and efficiently. Rapid access is a property of structure: records queryable by entity, by person, and by relationship — not documents that must be read one by one. This is where open data standards earn their place. A register that exports to the Beneficial Ownership Data Standard holds its data in a shape that any authority’s tooling, present or future, can consume.
Access is also a risk. A beneficial-ownership register holds exactly the information a corrupt insider would want to alter and an attacker would want to exfiltrate. The access requirement therefore carries a shadow requirement: every consequential action — a query by an authority, an edit, an erasure — must leave a tamper-evident trace. An append-only, cryptographically anchored audit trail is what lets a register prove, years later, that the answer it gave an authority was the answer its records held at the time, and that nothing was silently rewritten in between.
How RÉCOR is designed against these requirements
RÉCOR, a sovereign beneficial-ownership registry designed for Cameroon, is SIGIL’s answer to this reading of the standard, and it is designed to satisfy Recommendation 24 — a deliberate phrase, explained in the limits below. Adequate: its data model resolves every record to natural persons, types each interest — including nominee arrangements with the nominator identified — records the legal basis of control, and stores shares as integer basis points so that thresholds stay arithmetically exact. Accurate: nine verification stages stand between a declaration and publication — identity gates, sanctions and politically-exposed-person screening, adverse-media review, graph-pattern detection, and a fusion stage designed to say “we do not know” rather than force a verdict.
Up to date: each declaration is signed by the declarant together with a formal claim that it is adequate, accurate and up to date — the Recommendation’s own vocabulary, carried into the data — and the register is designed to re-screen published records as its sources refresh. Access and audit: records export to BODS v0.4 under a self-declared export profile, so the data stays structured and portable, and a triple-witnessed, Merkle-anchored audit chain makes every change tamper-evident, over a declaration log that is append-only at the database level.
RÉCOR was fully demonstrated to, and acknowledged by, Open Ownership on 1 July 2026. This is a technical demonstration, not an endorsement.
The honest limits
Two limits deserve plain statement. First, Recommendation 24 is assessed at the level of jurisdictions, not software. The FATF and its regional bodies evaluate countries through mutual evaluations; no software product is, or can be, certified as “Recommendation 24 compliant”. A registry system is assessed against the Recommendation, in the context of a country’s laws, obligations, enforcement, and institutions — none of which a vendor supplies. Good machinery can make a country’s compliance achievable; it cannot make it automatic.
Second, RÉCOR is pre-deployment. “Designed to satisfy” is a claim about engineering — the strongest claim we make, and the way we make claims generally is set out in our doctrine. What a deployed register achieves is decided by the institution that operates it and the jurisdiction that governs it, which is exactly where the Recommendation places the responsibility.
Frequently asked
What does FATF Recommendation 24 require?
Recommendation 24 requires countries to ensure that adequate, accurate and up-to-date information on the beneficial ownership and control of legal persons can be obtained or accessed rapidly and efficiently by competent authorities. Since the March 2022 revision it prescribes a multi-pronged approach: companies hold their own beneficial-ownership information, the information is also held by a public authority or body functioning as a beneficial-ownership registry or through an equally efficient alternative mechanism, and other existing sources supplement both.
What changed in Recommendation 24 in March 2022?
At its March 2022 Plenary the FATF adopted amendments that made the multi-pronged approach to collecting beneficial-ownership information explicit, raised the information standard to adequate, accurate and up-to-date with rapid and efficient access for competent authorities, prohibited new bearer shares and required existing ones to be converted or immobilised, strengthened transparency obligations on nominee arrangements, and required authorities to reach beneficial-ownership information during public procurement. Implementation guidance followed in March 2023.
Can software be certified as compliant with Recommendation 24?
No. The FATF assesses jurisdictions, not products, through mutual evaluations. A registry system is assessed against the Recommendation's requirements in the context of a country's laws and institutions; it cannot be certified by the FATF. RÉCOR is therefore described as designed to satisfy Recommendation 24 — an engineering claim, not a certification.