Why Knowing “Who Owns Whom” Matters More Than Ever in the Age of AI
In this blog, Clare Rowley, Head of Business Operations at GLEIF, explains the growing importance of Level 2 data in the Global LEI System for enabling trusted, interoperable organizational identity and encourages stakeholders to share their feedback to ensure it continues to meet evolving needs across the digital economy.
Author: Clare Rowley
Date: 2026-05-21
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Artificial intelligence (AI) is reshaping the global fraud landscape, with identity-related fraud, document manipulation, and AI-generated misinformation making it difficult to distinguish legitimate from unreliable content. Digital interactions can take place instantly across borders and jurisdictions, creating new complexities.
At the same time, regulators are increasingly focused on the challenges posed by the underlying data environments. For instance, in its recent interim report on the simplification of EU reporting frameworks for funds and transactions, the European Securities and Markets Authority (ESMA) highlighted how fragmented reporting systems, inconsistent data standards, and duplicative reporting requirements continue to create operational burdens and limit the usability of supervisory data.
ESMA’s simplification efforts emphasize the growing importance of interoperability, standardization, and more efficient data sharing across all reporting ecosystems. Whether in fraud prevention, regulatory reporting, or digital interactions more broadly, these developments point to the same underlying challenge: the need for trusted, interoperable, and verifiable organizational identity data.
The Importance of Who Owns Whom
This reflects that organizations increasingly need to identify not only "who is who," but also "who owns whom." A full understanding of organizational relationships is essential for risk management, due diligence, counterparty assessment, compliance, and market transparency. However, complex ownership structures, cross-border activities, and fragmented data environments make it difficult to establish a clear and reliable view of how legal entities are connected.
The Legal Entity Identifier (LEI) addresses this challenge. While it answers the question of “who is who,” it also helps answer “who owns whom” by providing trusted and standardized information – known as Level 2 data – on the direct and ultimate parent relationships of legal entities, where applicable. This helps organizations better understand ownership structures and relationships across jurisdictions and markets. GLEIF is actively working to ensure Level 2 relationship data continues to meet these needs, and invites stakeholders to share their input through a short survey.
Relationship Transparency as a Foundation for Trust
Yet to create meaningful value across interconnected digital ecosystems, we know that organizational identity data must be interoperable, accessible, understandable, current, scalable, and easy to integrate into operational workflows. Organizations require trusted, usable data that can move seamlessly across onboarding, compliance, reporting, payment, and digital identity systems across jurisdictions and sectors.
In this context, ESMA’s broader efforts to simplify reporting frameworks and reduce duplicative reporting highlight that efficient and reusable reporting models depend on entities being uniquely and consistently identifiable across systems and jurisdictions. When trusted organizational identity data flows efficiently, it reduces friction, improves transparency, and strengthens confidence in cross-border interactions and digital ecosystems.
As an internationally recognized and standardized global Digital Public Infrastructure (DPI), the Global LEI System supports this need by providing organizational identifiers that enhance interoperability across local and national infrastructures. This helps improve transparency, reduce friction in global markets, and enable more efficient and trustworthy interactions among businesses, regulators, financial institutions, and digital platforms.
AI Increases the Importance of Trusted Data
Importantly, data must be both trusted and interoperable. As AI models and autonomous agents become more integrated into operations and decision-making, they rely on structured prompts and verifiable data for reliable outcomes. If information and data are incomplete, inaccurate, outdated, manipulated, or unavailable, automated systems can amplify misinformation, reinforce errors, or produce unreliable results at scale.
GLEIF demonstrates how authoritative validation can help transform raw data into trusted data. By systematically validating entity reference data against authoritative sources and clearly disclosing the level of validation applied, the Global LEI System supports far greater transparency around data provenance and verification status. This helps reduce the risk of misinformation, strengthen model reliability, and support greater integrity across digital ecosystems.
Evolving the Global LEI System with the Market
As market needs continue to evolve, GLEIF and the Regulatory Oversight Committee (ROC) remain committed to aligning the Global LEI System with user needs and industry feedback. Level 2 relationship data is central to these efforts. Beyond regulatory reporting, it supports broader market transparency, improves organizational visibility, strengthens risk assessment capabilities, and enables new digital use cases.
This is why GLEIF invites stakeholders to participate in a short survey focused on enhancing Level 2 relationship data. Insights gathered through the survey will help identify where improvements can create the greatest impact, including enhancing usability, simplifying integration into workflows, strengthening interoperability, improving consistency, and better supporting evolving market needs.
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Clare Rowley is the Head of Business Operations at the Global Legal Entity Identifier Foundation (GLEIF). Prior to working with GLEIF, Ms. Rowley worked at the United States Federal Deposit Insurance Corporation where she led technology initiatives improving bank resolution programs and contributed to research on subprime mortgages. Ms. Rowley is a CFA® charter holder and holds a MS in Predictive Analytics from Northwestern University.
