How to Find the Beneficial Owner of an Offshore Company

ROBERT SOCHA*

Effective verification of a business partner primarily involves identifying the beneficial owners.

Finding the beneficial owner of an offshore company is often like searching for a needle in a haystack. It's challenging but possible. There's no single definitive and effective method, but skillfully combining technology, OSINT, and critical thinking can yield excellent results.

Official Registers

We usually start with official registers. This is, of course, the first and necessary step. Each country provides such registers differently. Some do not provide information on beneficial owners at all, while others charge for it. It’s worth remembering that unfamiliarity with rare or exotic languages shouldn’t deter us. Automatic translation options built into search engines are sufficient to guide us through obtaining official extracts and paying fees.

Countries like the Republic of Cyprus, the Republic of Seychelles, or the Cayman Islands also have official company registers. The information available there is usually minimal and rarely includes details on beneficial owners. However, it's worth checking these sources in our investigation, as every piece of information is valuable and can lead to further discoveries.

Formulate Hypotheses

Think like a prosecutor. If we suspect that person X or Y might be the beneficial owner, it's worth formulating such a hypothesis and verifying it by looking for evidence to support it. Sometimes, while examining the structure of a company, we discover that one of its partners is an offshore company. Then the question arises: who is the beneficial owner of that company? The official register may not necessarily reflect reality (though it should). If we assume that person X is the owner, it is worth using one of the tools that allow us to see the broader business network of the person and how they are connected.

Open Corporates

After checking the official registers, including those minimal ones in tax havens, the next step should be using the free and open OpenCorporates database.?

Its great advantage is that it allows you to simultaneously search corporate registers in over 140 different jurisdictions. We can then refer to specific national registers for further verification. This will give us a broader picture of current and historical connections. Perhaps a pattern will emerge? Maybe offshore companies appeared in other companies as well? Perhaps a personal key will emerge concerning the members of the various companies' bodies, collaborators of our subject?

It’s important to remember that the Open Corporates database is not complete and may be outdated, but it is still a huge help in identifying the international connections of the subject we are interested in.

Also, remember that some offshore companies conduct business activities or are partners in companies operating in countries with a higher degree of corporate transparency. Such companies must submit corporate reports in the country where they operate. This could be our backdoor to better understand the structure of the offshore company.

Leak Databases

Another important step in the investigation aimed at identifying the beneficial owner of an offshore company is using the Offshore Leaks database provided by the International Consortium of Investigative Journalists (ICIJ) . The database contains information about over 810,000 companies, foundations, and trusts from leaks known as the Panama Papers, Pandora Papers, Paradise Papers, and Bahamas Leaks. We can search the database by the company name or the name of a specific person. It is not a complete database of offshore companies, but it is a significant source of information about the relationships and associations of the visible entities and individuals. It should not be treated as an official source of information, but it is a critical source of clues that we can then verify through other sources.

Also worth remembering is the Aleph database maintained by The Organized Crime and Corruption Reporting Project (OCCRP). The database is available at a basic level to any user, with full resources available only to verified investigative journalists. It contains a very diverse range of data - from leaks, corporate information, financial data, etc.

Commercial Databases

At a certain stage of our research, we may hit a wall, finding ourselves with fragments of information that might fit our hypothesis but still lack confirmation. We will then face the necessity of using commercial tools, of which there are many, often expensive or very expensive (such as risk & compliance databases for corporate risk assessment). It's easy to fall into the trap of overestimating expensive tools and underestimating creativity and critical thinking.?

There are very good tools that allow you to search, for example, the Cypriot register. After purchasing access, we see registration documents, scans, company history changes, addresses, names of key persons - these can be significant clues confirming our assumptions. Even if the founders are just “straw men,” they are still real people. Maybe they appear in other companies? Perhaps a personal key will emerge? Maybe the registration address is repetitive or, for example, once appeared in a leak database as related to our subject? All these can be significant clues leading to the identification of the actual beneficial owner. Each such piece of information is a “selector” that can lead to further discoveries by cross-referencing it with other selectors.

Search operators

Commercial databases usually require us to log in and pay a fee. Without this, they allow only company name or registration number searches, but not by the name of a person visible in the register. This is the case, for example, with one of the Cypriot databases or one of the tools for searching companies registered in the Russian Federation and the former Soviet republics. However, a simple trick using the “site:” Google search operator can be used to search the database using a specific name before deciding to purchase a report from the database.

It's worth remembering that foreign names may have different spellings, especially those originally written in Cyrillic and translated into English or any other language. In my practice, I have also encountered cases of nationals whose original names in foreign registers were distorted. These could also be deliberate actions to make register searches more difficult.

Archived Websites

Sometimes, when analyzing complex ownership structures, we notice that someone has gone to great lengths to build a multi-layered cross-border structure where offshore companies are usually at the end. In such a situation, it is, of course, worth obtaining official extracts for each company in this chain, as it may turn out that in one of the jurisdictions, the register will show the beneficial owners of this particular company, which will also be a significant clue regarding the offshore company.

Additionally, it is definitely worth analyzing the archived websites of individual companies if they have them. Especially useful is the use of internet archives (Wayback Machine by Internet Archive and similar tools). This approach works particularly well for companies operating in the Russian market. Before Russia's invasion of Ukraine, many companies, including Western ones, officially reported activities in the Russian Federation. Today, even if the company still operates in Russia, it does not necessarily openly inform about it on its website.

One of the best movies about investigative journalism is 'Spotlight,' which tells the story of The Boston Globe journalists who exposed the massive scale of pedophilia in the Boston church. The film's editor-in-chief, Marty Baron, says that journalists spend most of their time wandering in the dark until they finally see the light. Similarly, finding the beneficial owner of an offshore company involves a lot of wandering until we stumble upon something and suddenly find the missing piece of the puzzle. It can be time-consuming and labor-intensive, and it is easy to get discouraged, but there is no other way. Perseverance and creativity are key.

ROBERT SOCHA - lawyer and a qualified prosecutor, former investigative journalist. Currently runs his own consultancy focused on sanctions screening & enhanced due diligence, crisis communications, and media training.

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