Transparency by Design: A Path Towards a U.S. Company Registry with a Single Identifier
Amy Edwards-Holmes
Amy Edwards Holmes is a nationally recognized expert in data strategy, analytics, and public sector innovation. She previously served as Executive Director of the Bloomberg Center for Government Excellence at Johns Hopkins University and as Deputy Assistant Secretary at the U.S. Department of the Treasury, where she led implementation of the DATA Act and launched major financial transparency reforms. As Partner and Principal of Holmes Consulting Group, she advises governments at all levels on harnessing data, AI, and digital transformation to improve service delivery and strengthen public trust.
Paper at a Glance
Ensuring that businesses are legitimate and that their formation is transparent is essential to safeguarding economic stability and public trust in the financial system. It is also vital to the integrity of public funds, since criminals can easily exploit opaque systems of business formation to steal public funds, launder money, and evade taxes.
Key Takeaways
Fragmented data systems are a structural vulnerability. Weak disclosure laws, nonstandard business data, and weak coordination between federal and state governments make it hard to trace ownership or detect risk across jurisdictions.
Standardization is essential to prevention. Harmonized data formats, interoperable identifiers, and cross-government data exchange would allow oversight bodies to detect suspicious networks, improve due diligence, and strengthen fraud prevention capacity.
The Legal Entity Identifier (LEI) provides a proven global model. Created in 2012, the LEI links entities to their owners through a single verifiable code that answers three core questions: Who is who, who owns whom, and who owns what.
The LEI alone is insufficient without beneficial ownership data. LEIs identify entities and corporate hierarchies, but they do not identify the natural persons who ultimately own or control companies. A complete solution needs both standardized identifiers and verified beneficial ownership disclosure.
A national company registry based on the LEI, supplemented with beneficial ownership information, would strengthen integrity, fairness, and trust across the U.S. business environment.
Citation
Edwards-Holmes, A. (2025, December). Transparency by Design: A Path Towards a U.S. Company Registry with a Single Entity Identifier. Program Integrity Alliance.
This work is licensed under Creative Commons Attribution-NonCommercial 4.0 International.