Case Studies

Michael provided support and advice to the Anti-Money Laundering Unit of Jordan’s Central Bank on drafting and implementing regulations to establish a beneficial ownership register for the Kingdom. At the time, Jordan was on the FATF grey list. Implementing the regulations was part of a suite of measures to remove Jordan from the grey list. Countries on the FATF grey list can experience a significant impact on attracting investment and on GDP.

Michael’s contribution included:

• Reviewing the relevant amendments to the Companies Act and AML law,
• Facilitating workshops involving a range of Jordanian government agencies both online and in person to make decisions on the policy inputs to the regulations and the detailed content,
• Reviewing draft regulations and providing feedback,
• Drafting the guidance document for companies to assist in compliance with the new regulations.

As a result of implementing these regulations and other measures undertaken by th government, Jordan was removed from FATF’s grey list.

Michael was the lead contributor for a new country entry report for a north American based mining company. The company was considering bidding for exploration licences in Egypt’s mining sector.

Michael provided:

• Interviews with contacts both in country and outside to gain insights,
• Detailed analysis of the business context for international mining companies in Egypt,
• Mapping of key government stakeholders in the mining sector and their agendas,
• A comprehensive assessment of the political risks faced by the client,
• Strategies to mitigate risks.

The analysis identified key risks stemming from the involvement of the military in the sector, the untested nature of recent legal and regulatory reforms and slow government decision-making. Using the analysis provided and the recommended mitigation strategies, the client went ahead with licence application and successfully established a presence in Egypt.

Michael, in collaboration with another consultant, conducted a human rights due diligence assessment for a major infrastructure project in Israel and the OPT to allow the leadership of major European engineering company to make fully informed  decision on whether to bid for a controversial project. The project had a long history of controversy and attracted legal action and boycotts.

Michael undertook desk top research, interviews with a range of stakeholders and conducted a field visit to Israel, the West Bank and East Jerusalem.  Interviewees included representatives of the client company, the Israeli government, foreign diplomats, the Palestinian Authority and both Israeli and Palestinian civil society. 

Michael and his colleague produced a detailed report which described the human rights context for the project, provided a comprehensive assessment of the project’s potential human rights impacts and set out the actions that the client would have to take to avoid any potential complicity in human rights abuses.  The client along with several other international companies that were considering bidding for the project decided against bidding, citing human rights concerns.    

Michael led two projects to advance beneficial ownership transparency of companies in the oil and gas sector in Iraq. The country implements the Extractive Industries Transparency Initiative (EITI). The EITI Standard includes provisions on the public disclosure of the ultimate owners of companies operating in the sector. Failure to implement the Standard can lead to suspension and Iraq had experienced one period of suspension. The country was also facing validation of its implementation.

Michael, in conjunction with Engaged Consulting, provided:

• A scoping study and gap analysis,
• In-person training to the Iraq EITI leadership team on beneficial ownership,
• Online training for companies in scope for reporting,
• Undertook two rounds of data collection,
• Provided actionable recommendations to promote sustainable implementation beyond the scope of the projects.

Iraq has avoided further suspension and successfully navigated the validation process. The Iraqi government has also introduced beneficial ownership obligations which cover the wider economy, beyond oil and gas.

Michael was a member of a multi-disciplinary team advising Egypt’s Ministry of Petroleum on internal governance reforms. The project was funded by the European Bank of Reconstruction and Development (EBRD). The project aimed to streamline and enhance the governance of essential internal processes such as exploration licence award.

Michael contributed to the project through:

• Providing inputs to the process to identify 20 key processes for reform,
• Mapping licence application and licence award processes and recommending reforms,
• Participating in workshops with Ministry of Petroleum and state-owned company senior officials,
• Undertaking political economy analysis,
• Advising on international standards on transparency,
• Stakeholder engagement.

Michael was a member of a team of international and Azerbaijani consultants who delivered support to the State Oil Fund of Azerbaijan to implement a beneficial ownership disclosure roadmap.  The project was funded by the Asian Development Bank and included:

• An inception visit and report,
• Analysis of international good practice using six comparator countries and international standards such as FATF and EITI,
• A definition of beneficial ownership,
• The mechanism required for implementation, administration and verification,
• Legal review,
• Draft implementing legislation,
• A public consultation process,
• Awareness raising activities including producing an explanatory video.

Michael and the team delivered the project through a combination of permanent on the ground presence, carefully planned field visits and remote working. The result was the delivery of package for the implementation of a beneficial ownership reporting and disclosure regime that had buy in from all key stakeholders including government, industry and civil society.

Michael was a member of a team of international and Ghanaian consultants delivering economy-wide beneficial ownership transparency in Ghana, funded by the British government. This was the first public beneficial ownership register in Africa. Ghana amended its Companies Act to implement a public beneficial ownership register as part of efforts to enhance trust in its business environment.  The Registrar-General requested technical assistance with implementing the provisions. 

Michael supported:

• A review of the new Companies Act legislation to assess areas to be included in regulations and guidance
• Drafting of regulations and guidance for approval by the Registrar General
• Design of reporting templates and detailed instructions for completion
• Advice on a phased roll-out of the beneficial ownership reporting regime
• Advice on methods of verification of beneficial ownership data
• Workshops and training for a range of stakeholders
• Technical input to the scripting of informational videos on the fundamentals of beneficial ownership

This was successfully delivered by a combination of local face-to-face engagement and remote working.