UBO-register access changes in Marshall Islands: recovery implications

As of mid-2025, the Marshall Islands has moved to tighten the conditions under which beneficial ownership information held in its corporate register can be accessed by third parties. The change is narrow on paper. Its consequences for cross-border recovery practitioners are not.

For anyone tracing assets through a Marshall Islands entity – a registered agent, a nominee-held LLC, a flag-of-convenience structure used to receive or layer stolen funds – the practical question is whether the beneficial ownership record remains reachable through the recovery toolkit. The short answer: coordinated legal process still works, but the window and method have shifted, and local admitted counsel must now be engaged earlier than before.

This alert covers what changed, who is affected, and the steps practitioners should take now.

What Has Changed in the Marshall Islands UBO Register?

The Marshall Islands has historically operated a non-public UBO register: beneficial ownership information was collected but not freely accessible to third parties or foreign authorities on demand. Recent amendments have further restricted the conditions under which that register can be queried, tightening the gateway between a requester and the underlying beneficial ownership data.

In practical terms, the change means that automatic or administrative disclosure to foreign law enforcement or private litigants is harder to obtain. Requests now require a more formal showing of legal basis. The register has not been abolished – it still exists, and the data is still held. Access, however, now requires coordinated legal process rather than a direct administrative request.

For recovery practitioners, the substance of the shift is timing and process, not the total loss of a route. A Norwich Pharmal order, a Bankers Trust order, or equivalent disclosure mechanism obtained from a competent court can still compel production of the underlying ownership record. What has changed is the threshold showing required before that compulsion takes effect.

Who Is Affected by These Access Changes?

The affected population is broader than it first appears. Marshall Islands entities are a standard feature of offshore corporate architecture. We regularly advise on matters where the LLC at the end of a payment trail – the vehicle that received a wire transfer, held a crypto wallet, or issued a fraudulent invoice – is registered in the Marshall Islands precisely because of its historically light disclosure environment.

The categories most directly affected include:

• Insolvency practitioners seeking to identify the beneficial owners of counterparties that stripped assets before a company entered administration.
• Fraud victims whose funds moved through a Marshall Islands entity en route to a crypto exchange or a secondary jurisdiction.
• Referring lawyers advising on the viability of a claim where the defendant's corporate structure runs through the Marshall Islands.
• Litigation funders assessing the recoverability of a judgment where enforcement depends on piercing a Marshall Islands shell.

In our experience, the Marshall Islands sits in the middle layer of many layered offshore structures – rarely the endpoint, frequently the anonymising vehicle between a fraud and the final cash-out point. Changes to register access therefore affect asset recovery Marshall Islands matters at a structurally important chokepoint.

What Practitioners Should Do Now

The adjustment required is procedural, not strategic. The instruments available for compelling ownership disclosure remain intact. What changes is when you engage local counsel and what you ask them to prepare.

Three immediate steps matter:

• Engage local admitted counsel in the Marshall Islands at the outset, not after you have exhausted other routes. The gateway to the register now runs through the local legal system, and the threshold showing is one that needs to be built from the beginning of the matter.
• Identify whether on-chain tracing can establish the wallet associated with the Marshall Islands entity independently of the register. Public blockchains are transparent; on-chain tracing can attribute a wallet to an entity even before the beneficial owner is identified. That attribution, combined with a disclosure order, is often more powerful than a register query alone.
• Preserve all available evidence of the entity's involvement before seeking formal disclosure. A Bankers Trust order or equivalent directed at the receiving bank may yield account-opening documentation that identifies the UBO independently of the register.

Assets move faster than amended procedures. Where crypto is involved, an on-chain trace to a centralised exchange or a virtual-asset service provider (VASP) choke point can be pursued in parallel with the corporate disclosure process – hours matter at that stage of a recovery.

If you are assessing a matter involving a Marshall Islands entity and stolen or misappropriated funds, the steps above describe the general direction. Your matter turns on specific facts – where the money is now, which forums can act, and whether the ownership record is reachable in the time available. To discuss whether your matter is worth pursuing, contact us at info@axiomtracel.com.

Related Insight from Axiom Trace

• Crypto asset recovery – cluster overview and guides
• Marshall Islands jurisdiction profile – recovery considerations
• How a phishing attack works and where the money goes

About Axiom Trace

Axiom Trace is an independent boutique focused on cross-border and crypto asset recovery. We trace assets that have moved across borders or on-chain and coordinate their freezing and recovery – working with defrauded principals, insolvency practitioners, and the lawyers and funders who refer them. We work lawfully and within applicable sanctions regimes, alongside local counsel where proceedings must be filed. We have traced funds through Marshall Islands entities and coordinated the disclosure and freezing process across multiple forums. Our approach starts with the evidence available on-chain and in the corporate record – not with a promise of what the outcome will be. To discuss a matter, contact info@axiomtracel.com.

Disclaimer: This publication is for general information only and is not legal advice, nor a promise or prediction of recovery. No outcome is guaranteed. Asset recovery depends on the specific facts and on the law and procedure of each relevant jurisdiction, where local admitted counsel must act. Axiom Trace coordinates closely with admitted local counsel in the Marshall Islands; local procedure governs the filing. Axiom Trace assumes no liability for actions taken or not taken based on this material. For advice on your situation, contact info@axiomtracel.com.