23 September 2025 –

Illicit assets are rarely held in someone’s name directly. Instead, they are often hidden behind complex legal structures, making it essential to identify the real beneficial owner before asset recovery can begin. The interlinkages between asset recovery and beneficial ownership transparency was the topic of discussion at the 20th Asset Recovery Working Group meeting, where expert presentations were held by Transparency International, and Open Ownership. They discussed the new Opacity in Real Estate Ownership (OREO) Index by Transparency International and the Anti-Corruption Data Collective (ACDC), followed by a deep-dive into how beneficial ownership transparency can strengthen asset recovery.

The new OREO index

It is a well known fact that real estate is one of the most common channels for corrupt actors to launder and conceal their dirty money. The OREO index assesses 24 jurisdictions on the extent to which they can protect their real estate markets from such abuse and deter dirty money before it enters, but also detects properties purchased with suspicious assets. This latter goal is particularly relevant to asset recovery, and the index examines whether tracing suspicious assets and identifying who ultimately owns the properties is possible in G20 heavyweights and financial hubs such as Hong Kong, Singapore and the United Arab Emirates. Without making this connection, it’s very difficult to kick off the asset recovery process, let alone be successful in returning assets.  

The OREO Index is able to provide this information through two pillars: 

• The data pillar – assessing data availability, openness, and completeness
• The legal pillar –  evaluating the strength of anti-money laundering frameworks, including due diligence requirements, beneficial ownership rules, supervision, and sanctions.

Findings show none of the countries analyzed achieved a perfect score, and all have loopholes. For example, in Singapore – ranked second on the index – real estate data was found to be restricted and far from open. 

Overall, the index showed it is still possible in the majority of cases to own property anonymously, due to multiple gaps that allow real owners to remain hidden. For example, many countries still allow foreign companies to execute real estate transactions without disclosing their beneficial owners. Another common problem is related to the lack of scrutiny of real estate transactions by regulated professionals. For example, the index showed that anti-money laundering obligations are often not extended to real estate developers, even if they are allowed to buy and sell property on behalf of clients. Finally, the index draws attention to the limited access to real estate data, which undermines civil society’s ability to perform our watchdog roles, and presents barriers even to authorities when investigating suspicious cases.  

Beneficial ownership transparency

Open Ownership presented how beneficial ownership transparency can strengthen asset recovery through research designed around user-centered reforms. The research emphasizes the importance of reforms that provide practical, usable information, creating real impact on the ground.

A key element is understanding the different relationships between individuals, legal vehicles and assets–recognised as beneficial ownership networks. Understanding these networks involve connecting the dots between different sources of information, including asset registries, and then complementing them with other sources of information about legal vehicles, often across borders. To this end, the EU has made significant progress in beneficial ownership registers for legal vehicles but there remains a need for legal and technical standardization to combine information about the beneficial ownership of legal vehicles with information in asset registers and other data sources. 

To tackle challenges, a whole-of-government approach is needed so that the legal basis for collecting and accessing information about the beneficial ownership of legal vehicles is not just limited to anti-money laundering but also for broader purposes. This is the case in Norway where an approach has been proposed to enable the effective functioning of companies and to prevent any misuse of assets. Beyond national reforms, effective frameworks are also needed for cross-border access, with the ultimate goal of a single search being able to look through multiple interconnected registers.

Both presentations underscored the importance of transparency in asset recovery, as without clear information recovery efforts remain stagnant. Strengthening beneficial ownership systems by closing gaps in the data are vital steps toward ensuring stolen assets can be traced, recovered, and returned.