As beneficial ownership (BO) transparency becomes a central pillar of anti-money-laundering reform worldwide, countries are racing to build registries that expose who really controls companies, trusts, and other legal structures. South Africa, following its exit from the FATF grey list, is accelerating the development of its own national Beneficial Ownership database—an evolution that will reshape compliance expectations for all accountable institutions from 2026 onward.

To understand where South Africa is headed, it is instructive to examine how BO verification currently functions in two rapidly evolving jurisdictions: Ghana and the United Arab Emirates (UAE). Both countries, in different ways, offer lessons on what works, what regulators value, and what challenges lie ahead for institutions required to perform due diligence.

This article, the third in ThisIsMe’s KYC/FICA 2026 Compliance Series, provides a comparative overview of global BO trends, explains how these experiences can inform South Africa’s next steps, and assesses how the emerging South African BO register will influence KYC and FICA compliance in the years ahead.

How Beneficial Ownership Verification Works in Other Countries

Around the world, regulators increasingly view beneficial ownership visibility as the linchpin of an effective AML/CFT system. Hidden control structures, opaque trusts, and layered offshore entities are some of the most common vehicles used to conceal proceeds of corruption, tax evasion, and organised crime. As a result, many countries have moved quickly to create registries that allow banks, regulators, and law-enforcement agencies to identify the real natural persons behind legal entities.

Ghana: Pragmatic, Risk-Focused Implementation

Ghana has been widely praised for developing one of West Africa’s more coherent BO frameworks. Through its Companies Act reforms and the establishment of the Registrar-General’s Department’s BO Register, Ghana has created a practical, risk-driven structure that prioritises accuracy and accessibility.

Three features define Ghana’s approach:

• A centralised BO Register linked to corporate filings, enabling regulators and financial institutions to check declared BO information against official records.
• Mandatory BO disclosures for companies, partnerships, and certain trusts—supported by legal obligations to keep information current.
• Growing interoperability with other state data systems, which allows discrepancies to be identified more quickly and investigations to proceed more effectively.

While challenges remain—particularly around data accuracy, enforcement capacity, and the technological maturity of the registry—Ghana has positioned itself as a regional leader. Its model demonstrates that even in developing markets, BO transparency can be implemented in a way that supports both compliance and economic growth.

The UAE: High Standards Driven by International Scrutiny

The United Arab Emirates, once criticised for financial secrecy and complex offshore structures, has undergone an aggressive transformation in response to FATF pressure. Its BO verification regime, introduced through Cabinet Decision No. 58 of 2020 and strengthened in subsequent legislation, is now considered one of the more stringent in the Middle East.

The UAE system is characterised by:

• Strict mandatory BO filings for nearly all entities operating in the mainland and free zones (with limited exceptions such as the DIFC, which has its own regime).
• Robust enforcement, including administrative fines for delayed, incomplete, or inaccurate submissions.
• A deeply risk-oriented supervisory approach, where regulators expect financial institutions to verify BO information independently rather than rely solely on registry data.
• Active supervisory follow-up, with the UAE adopting sophisticated technology to flag high-risk structures, nominee arrangements, and foreign-controlled entities.

The UAE example highlights the direction global AML systems are moving: toward integration of registry data, proactive supervision, and strong penalties for non-compliance. In many ways, the UAE’s transition offers a preview of what South Africa’s regulatory ecosystem may eventually resemble.

How South Africa’s Developing BO Database Will Change Compliance from 2026 Onward

South Africa’s Beneficial Ownership Register, administered by the CIPC and mandated under amendments to the Companies Act and FIC Act, is still maturing. But early indications suggest it will become one of the most consequential regulatory tools in South Africa’s post-greylist landscape. As the database expands and improves, it will fundamentally reshape how accountable institutions perform KYC, build risk models, and present evidence to supervisors.

A New Level of Transparency

The introduction of a centralised BO database marks a significant shift away from South Africa’s historically decentralised and often opaque business transparency system. For the first time, institutions can compare client-supplied BO information with a government-maintained record. This reduces reliance on self-declaration and helps identify discrepancies that previously went unnoticed.

As the database improves, regulators will expect institutions to explain why any inconsistencies were not flagged, escalated, or verified. In other words, access to registry data increases accountability.

Higher Standards for Verification and Documentation

With a functioning BO register, verifying ownership structures is no longer optional or interpretative. Institutions will be expected to:

• Document how they compared client information with CIPC data
• Explain how they resolved mismatches or gaps
• Maintain updated records whenever a company files BO changes
• Strengthen their RMCP to reflect the existence of a national BO reference point

The days of “best effort” beneficial ownership checks are ending. From 2026 onwards, verification must be demonstrable, defensible, and aligned to registry information unless there is a compelling, documented reason otherwise.

More Sophisticated Risk Models

South Africa’s BO database unlocks new possibilities for customer risk modelling. Institutions will be able to incorporate:

• BO complexity as a quantifiable risk factor
• Frequency of BO changes
• Whether BOs are politically exposed persons (PEPs)
• Jurisdictional linkages (e.g., whether BOs reside in high-risk regions)
• Cross-referencing of adverse media or sanctions exposure

This improves both the accuracy of risk ratings and the integrity of ongoing monitoring.

A New Era of Regulatory Supervision

Regulators will gain immediate visibility into whether institutions are performing BO checks correctly. During audits, the FIC and other supervisors may request that institutions justify:

• Why a BO inconsistency was not detected
• How a high-risk BO structure was evaluated
• Whether adverse media or sanctions hits tied to BOs were spotted
• How client files were updated as the register evolved

This aligns South Africa with global trends: registries are no longer passive repositories—they are active compliance and enforcement instruments.

Lessons from Ghana and the UAE: What South Africa Should Prioritise Next

Ghana and the UAE demonstrate that BO systems succeed when three things are present: clear rules, technological maturity, and visible enforcement. As South Africa refines its register, these lessons matter.

South Africa’s priorities for 2026 should include the following:

• Data accuracy initiatives, including automatic prompts for companies with outdated BO filings.
• Stronger enforcement for entities that fail to submit or update BO information.
• Enhanced interoperability, such as linking the BO database to identity systems, tax data, and trust registers.
• Improved access protocols for financial institutions to reduce friction during onboarding and monitoring.
• Clearer regulatory guidance on how institutions should treat BO mismatches, nominee arrangements, and multi-layer structures.
• Support for SMEs, which often struggle with the complexity of BO obligations.
• Targeted supervision for high-risk sectors, including estate agents, attorneys, and trust service providers.
• These changes will help ensure that the BO register becomes an operational tool rather than a procedural requirement.

What This Means for Accountable Institutions Right Now

With South Africa entering this new era of transparent ownership, accountable institutions must modernise their KYC processes to align with the national shift. This includes:

• Updating RMCPs to reflect registry use
• Ensuring BO verification procedures rely on both client declarations and registry data
• Strengthening adverse media and PEP screening for BOs
• Implementing monitoring triggers tied to BO changes
• Ensuring documentation practices reflect a consistent, defensible verification trail

Institutions that adapt early will face fewer supervisory challenges and enjoy smoother audits. Those that cling to outdated processes will increasingly fall behind—and may face heightened enforcement attention in 2026 and beyond.

The Strategic Advantage of Getting BO Right

Beneficial ownership verification is no longer a niche compliance task; it is the backbone of modern AML/CTF systems worldwide. South Africa’s evolving BO register will raise expectations for accuracy, consistency, and documentation across all sectors.

Companies that master BO verification will benefit from:

• Faster onboarding cycles
• Reduced compliance friction
• Stronger audit outcomes
• Greater trust from international partners
• Lower exposure to reputational risk

As the regulatory landscape continues to evolve, accurate, efficient, and transparent BO verification is becoming not just a compliance requirement—but a competitive advantage.