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Sierra Leone

Beneficial Ownership Registry (SL0025)



Action Plan: Sierra Leone Action Plan 2019-2021

Action Plan Cycle: 2019

Status: Active


Lead Institution: Corporate Affairs Commission

Support Institution(s): Transparency International Sierra Leone; Campaign for Good Governance; Society for Democratic Initiatives; Institute for Governance Reform; Centre for Accountability and the Rule of Law

Policy Areas

Anti-Corruption, Beneficial Ownership, E-Government, Extractive Industries, Legislation & Regulation, Legislative, Private Sector

IRM Review

IRM Report: Sierra Leone Design Report 2019-2021

Starred: Pending IRM Review

Early Results: Pending IRM Review

Design i

Verifiable: Yes

Relevant to OGP Values: Access to Information

Potential Impact:

Implementation i

Completion: Pending IRM Review


What is the public problem that the commitment will address?
In 2016, the Extractive Industry Transparency Initiative
(EITI) established a requirement that all implementing
countries, of which Sierra Leone is one, should, by 2020,
require all mining, oil and gas companies to disclose the
identity of their beneficial owners. In addition, any
politically exposed persons (PEPs) who are beneficial
owners must be identified.
Furthermore, it is worthy to note that as Foreign
Investments are pivotal to Sierra Leone’s economic
development enormous effort is being made by
government to encourage foreign investments to boost
the country’s ailing economy. Notwithstanding, there is
the ardent need to ensure that there is integrity,
transparency, accountability and prudent financial
management in all foreign investments. To ensure this,
there is the need for adequate and transparent
information to be available of the nature of all foreign
investment ventures, to ensure that they are worthy,
credible and purposeful investments. This will go a long
way to forestall the unfortunate situations that the country
has faced regarding foreign investments that have
proved to be fraudulent, masterminded by politicians for
their personal benefit and these have ended up in
companies neglecting their corporate social
responsibilities and abuse the human rights of their
workers and communities in which they have operated
with impunity with dire consequences. In view of this,
there is the need for a more proactive beneficial
information disclosure regime in all foreign investments
in the country. This is of necessity as once this is
obscure it gives room for all negative consequences
faced so far in terms of foreign investments

What is the commitment?
Beneficial Ownership disclosure or Transparency has
become a growing interest at global and national levels.
This interest not only focuses on corporate beneficial
ownership information disclosure but also seeks to
expose conflict of interest among public office holders
otherwise known as Politically Exposed Person (PEPs).
It derives from the need to trace criminals who hide their
identities behind corporate structures to defraud
countries through corruption, tax evasion, undue
favoritism, money laundering and illicit financial flows.

How will the commitment contribute to solving the public problem?
Presently Sierra Leone does not have a Comprehensive
Law on Beneficial Ownership Disclosure not a
comprehensive database of all companies operating in
all sectors. To this end the Sierra Leone Extractive
Industry Transparency Initiative conducted a Legal and
Institutional Review of Beneficial Ownership Disclosure
in Sierra Leone. Action is yet to be taken to bring this to
fruition. As it stands, this will pose a challenge even with
Sierra Leone being regarded as compliant with the EITI
requirement specified above by 2020.

Why is this commitment relevant to OGP values?
Beneficial ownership disclosure is relevant because it will
help to promote transparency and credibility of foreign
business investments. It will safeguard against fraudulent
and self- seeking investments especially by public
official. It will ensure compliance with the local and
international laws and standards. Furthermore, it will
assist in promoting the anti-corruption and anti-money
laundering campaign.It will ensure that foreign
investments in the country contribute positively to growth
and sustainable development which will in turn help the
government deliver on its campaign promises and
ultimately fulfill the aspirations of citizens for effective
national development.


  1. Expanding Community-Based Justice Services

    SL0022, 2019, Access to Justice

  2. Improving Access to Secondary School

    SL0023, 2019, Education

  3. Tax System Transparency

    SL0024, 2019, Fiscal Openness

  4. Beneficial Ownership Registry

    SL0025, 2019, Anti-Corruption

  5. Improve Implementation of Right to Access to Information

    SL0026, 2019, Access to Information

  6. Advancing Gender Equality

    SL0027, 2019, Access to Justice

  7. Open Parliament

    SL0028, 2019, Capacity Building

  8. Records and Archives Management

    SL0029, 2019, Access to Information

  9. Gender

    SL0012, 2016, Capacity Building

  10. Foreign Aid Transparency

    SL0013, 2016, Access to Information

  11. Waste Management

    SL0014, 2016, Capacity Building

  12. Fiscal Transparency and Open Budget

    SL0015, 2016, Access to Information

  13. Audit Report

    SL0016, 2016, Anti-Corruption

  14. Climate Change

    SL0017, 2016, Access to Information

  15. Elections

    SL0018, 2016, Access to Information

  16. Record Archive Management

    SL0019, 2016, Access to Information

  17. Access to Justice

    SL0020, 2016, Access to Justice

  18. Open Public Procurement Contracting

    SL0021, 2016, Anti-Corruption

  19. Publish and Revise 70% of Mining and Agricultural Lease Agreements and Contracts

    SL0009, 2014, Access to Information

  20. Starred commitment Right to Access Information Law

    SL0010, 2014, Access to Information

  21. Open Data Portal for Transparency in Fiscal and Extractive Transactions

    SL0011, 2014, Access to Information

  22. Public Integrity Pact with 5 Ministries, Departments, and Agencies

    SL0001, 2014, Anti-Corruption

  23. Archives and Records Management Act

    SL0002, 2014, Access to Information

  24. Scale up Performance Management and Service Delivery Directorate

    SL0003, 2014, Public Participation

  25. Compliance with Audit Measures

    SL0004, 2014, Anti-Corruption

  26. Starred commitment Single Treasure Account

    SL0005, 2014, Anti-Corruption

  27. Extractive Industry Revenue Act

    SL0006, 2014, Anti-Corruption

  28. Scaling up Extractive Industry Transparency Initiatives

    SL0007, 2014, Anti-Corruption

  29. Local Content Policy (LCP) Linkages with MDAs

    SL0008, 2014, Capacity Building

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