Despite renewed regulations, law enforcement and financial investigators in the European Union continue to face serious obstacles in tracing who really owns what — especially when it comes to assets held through complex structures. A recent report from Transparency International finds that registers of legal ownership are often incomplete, fragmented, or out of sync with registers of beneficial ownership. This leaves significant loopholes that corrupt actors and financial criminals can exploit.
Investigators in several EU countries report that while major asset types — real estate, motor vehicles, watercraft, aircraft — may be registered, details such as transaction price, beneficial ownership, and ownership through companies or trusts are frequently missing or hard to access. Under current rules, only the registered legal owner is listed in many systems. If the asset is held indirectly, critical information about the person benefitting most is often inaccessible or only discoverable through difficult cross-referencing. Delays in access, lack of standard formats or machine-readable registers, and restrictive jurisdictions complicate efforts to investigate illicit flows.
The problem is compounded by weak oversight for “professional enablers” — lawyers, accountants, corporate service providers, real estate brokers — who can help establish opaque ownership chains. Transparency International’s priorities emphasize that these actors must be subject to stronger regulation, clearer duties to check and report suspicious structures, and robust sanctions for failing to do so. Golden visa and golden passport schemes are cited as especially vulnerable: investors abroad can gain residency or citizenship in exchange for real estate investment under frameworks that have sometimes allowed weak checks on the ultimate beneficiary of the investment.
While EU legislation has made advances — such as the 6th Anti-Money Laundering Directive (AMLD6) and the updated Anti-Money Laundering Regulation — which expand requirements for registering beneficial ownership and broaden reporting obligations (including those for crypto assets and certain asset classes like watercraft or aircraft), member states’ implementation remains inconsistent. Some are ahead, having laws and registers largely compliant; others still lag in transposing rules or filling transparency gaps, especially around assets held through foreign companies or trusts.
Investigators also report that even when registers exist, their utility is limited by poor digitalization, incomplete data sharing between registries, and insufficient tools for data analysis. Authorities in several countries say they lack full access to ownership registers, whether due to legal restrictions, national law, or lack of interoperability. Transparency International’s research argues that for anti-corruption and asset recovery efforts to be effective, public authorities need fast, reliable access to comprehensive ownership and transactional data, ideally via centralized and interlinked registers.
The “Dirty Money” agenda underlines several areas where enforcement is also weak: inadequate sanctions for misuse, lack of clarity in legislation governing beneficial ownership and real estate ownership, and limited resources for law enforcement, financial intelligence units, and asset recovery offices. According to Transparency International, only a fraction of assets stolen and hidden globally are ever seized, let alone returned.
To strengthen the EU’s ability to trace and recover illicit assets, the report calls for harmonized minimum standards across all member states, full transparency in ownership of real estate, vehicles, aircraft, and vessels, mandatory reporting of beneficial owners for all types of legal entities, and greater powers for authorities and civil society to access and scrutinize data. Strong, enforceable oversight and meaningful penalties for noncompliance are also highlighted as essential.
In short, while European law has moved forward in closing some gaps, much of the framework remains untested in practice. The effectiveness of recent reforms will depend heavily on how quickly and thoroughly member states overcome technical, legal, and institutional barriers — and how seriously they treat the risk posed by dirty money.
Source: Transparency International
