In this episode of Integrity Insights, Filip is joined by Michael Hornsby and Elisabetta Marinoni, researchers working with Transparency International and the Anti-Corruption Data Collective (ACDC), to discuss their new study: the Opacity in Real Estate Ownership (OREO) Index.

The conversation explores how opaque real estate ownership structures enable corruption and money laundering, why data and legal frameworks both matter, and what their assessment of 24 jurisdictions reveals about global weaknesses in this sector.

Key themes discussed:

Why real estate matters for financial crime

Real estate remains a preferred vehicle for laundering illicit funds. High-value transactions and the ability to hide behind corporate structures make it attractive to corrupt actors and criminals.

What the OREO Index measures

The index evaluates 24 jurisdictions, including G20 economies and major financial hubs such as Hong Kong, Singapore, Panama and the UAE.
It assesses two pillars:

• Data – the availability, completeness and openness of property and ownership data.
• Legal framework – the strength of AML rules governing real estate transactions and professionals.

The biggest loophole: missing beneficial ownership data

Most countries do not collect beneficial ownership information when property is registered.
This means properties can be owned anonymously through companies, especially foreign companies, making it extremely hard for authorities or journalists to trace real ownership or identify patterns of suspicious acquisitions.

Cross-border gaps and obstacles for investigators

Foreign companies can often buy property without any local presence, meaning no local BO disclosure. Investigators must then rely on the rules—and cooperation—of the company’s home jurisdiction, which is often limited or opaque.

Cash purchases and absence of gatekeepers

Some countries allow property purchases in cash and do not require involvement of notaries or lawyers.
This bypasses banking-sector AML controls and removes an important oversight layer.

Uneven AML obligations for real estate professionals

While most countries extend AML requirements to real estate agents, developers and lawyers are often excluded, creating entry points for money laundering.
In some jurisdictions, lawyers can even refuse to submit suspicious transaction reports due to client-privilege provisions.

Weak supervision and fragmented oversight

Supervision is often fragmented across many bodies—Germany, for example, has over 300 supervisory authorities in the non-financial sector—making consistent enforcement difficult.

How jurisdictions compare

• South Africa ranks high on paper, but enforcement gaps remain.
• Germany scores well legally but poorly on data transparency.
• Singapore and Hong Kong perform relatively well, though Hong Kong maintains weaker BO rules.
• The UAE scores poorly, reflecting high anonymity and the “open door” model that has historically attracted illicit funds.

Future outlook: risks of backsliding

Despite years of debate, there is still no global consensus that beneficial ownership transparency in real estate is essential. 

Read the full report here: https://www.transparency.org/en/publications/opacity-in-real-estate-ownership-index-2025 

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