One click away? The barriers investigators face across the EU when tracing asset ownership

Unlike science fiction, where authorities can tackle crime before it happens, investigations into cross-border corruption and money laundering schemes usually only start, if at all, long after illegal activities and payments have occurred. Authorities need to reverse-engineer the scheme, starting from the end. Information on the assets that criminals purchase and own is crucial for following the trail, and enables authorities to produce high-quality financial intelligence and pursue significant corruption-related money laundering cases.

Transparency International sought to understand the extent to which financial intelligence units (FIUs) and law enforcement agencies (LEAs) can, in practice, access and use ownership data to tackle corruption. To do so, together with our national chapters, we researched the access of competent authorities – that is, the official bodies legally empowered to act, such as FIUs and LEAs – in nine EU countries: France, Germany, Ireland, Italy, Latvia, Lithuania, Portugal, Slovenia and Spain. We conducted surveys of FIUs and LEAs, interviewed analysts and agents, and sent formal requests for information to authorities responsible for registers. Only for Portugal, neither the FIU nor the LEA provided answers to our surveys.

In an ideal world, corruption investigators could enter a suspect’s name into a database and – within one click – instantly see all the companies, trusts, properties, yachts, and aircraft connected to that individual. Authorities could then move swiftly to freeze assets, prevent their dispersal and pursue confiscation of ill-gotten gains. They could also then investigate the individual’s network to see if any of the companies, trusts or nominees lead them to additional cases of illegal activity.

In reality, however, authorities across the EU must spend days, sometimes weeks, piecing ownership information together among separate, disparately held registers across jurisdictions. This results in significant time needed to find, clean and verify information before it can be used. Tracing assets should and can work more seamlessly.

Asset ownership data plays an important role in investigations and production of financial intelligence. The new EU Anti-Money Laundering Directive, adopted in 2024, mandates that competent authorities must have direct, unfiltered, immediate and free access to beneficial ownership information by July 2026.

Most authorities told us they can easily access the beneficial ownership information of legal entities and trusts – crucial for connecting the dots between natural persons, the legal entities they control and the assets these entities hold. All assessed FIUs and LEAs also have direct access via public registers to key information on legal entities. FIUs and LEAs generally have direct access to company and bank account data, and, in most cases, to land and real estate data and the register of motor vehicles. The exception is Germany, where LEAs’ access to bank account data is possible on request via the financial regulator BaFin; the FIU should have direct access but in practice access is mediated due to IT interface issues. For both authorities, land and real estate data is not directly accessible for some states.

For other assets, FIUs tend to have stronger access than other authorities. In many countries, LEAs must request access to ownership data on certain asset types.

Across the board, however, the lack of structured crypto-asset registers is a common barrier for FIUs and LEAs. New EU regulations will soon oblige crypto-asset accounts be reported to national bank account registers and included in the Bank Account Register Interconnection System (BARIS) by July 2029.

Some countries also provide public datasets. Latvia’s beneficial ownership data, as well as legal entity data, is available publicly. Legal entity data is also available as downloadable bulk datasets in Lithuania and in Slovenia. Public registers for other types of assets – also then accessible by authorities – exist in limited cases. A limited number of publicly available datasets exist for specific asset types held by legal entities (such as real estate in France or bank accounts in Slovenia), but this is an exception rather than the rule across countries.

Over the past decade, EU co-legislators have significantly advanced the legal framework for ownership transparency in the EU. However, competent authorities still face some obstacles in effectively accessing and using ownership data to tackle corruption schemes.

In practice, authorities face disconnected registers that pose barriers for investigations and systematic analysis.

All nine countries we reviewed require authorities to conduct time-consuming cross-referencing across disparate registers to link beneficial owners, legal vehicles and asset ownership. In all countries, asset registers do not display the beneficial owner directly if an asset is owned by a legal entity – except for bank accounts. This means law enforcement agents and financial intelligence analysts need to manually construct links between beneficial owners, legal entities, and assets.

For example, the French FIU reported frustration with a lack of data-matching software at the national level – requiring analysts to painstakingly stitch together unconnected domestic asset registers, each maintained under different standards and access rules, for the information they need.

Spanish law enforcement authorities pointed out that they face significant challenges in tracing ownership of certain assets such as ships and aircraft. Investigators interviewed for this report explained that when they receive requests from foreign counterparts, such as whether a suspect owns a ship registered in their jurisdiction, they often cannot provide a straightforward answer.

The challenge presented by disconnected registers is multiplied for cross-border investigations typical for corruption-related money laundering cases. In response to the challenge of cross-country access, the EU introduced the Beneficial Ownership Registers Interconnection System (BORIS) as a centralised access point for EU-wide beneficial ownership data.

Access to asset ownership information depends on a patchwork of legal provisions and inter-agency agreements. Some authorities’ powers to access information are clearly defined in law, while others rely on opaque arrangements. A 2019 EU directive on the use of financial information requires member states to designate competent authorities (typically, at least the FIU) to have direct and immediate access to bank account information. FIUs generally also enjoy direct access to beneficial ownership and company registers. For other authorities and for other asset types – such as real estate, watercraft or aircraft – the type of access can depend on bilateral or inter-agency agreements. This means that the details of how access to information is provided in practice is not always publicly known.

Yet even formal power to access information does not mean that access is smooth and frictionless. In practice, the process of getting access can be slow and require extra steps, such as submitting case-by-case requests. Our research found that FIUs and LEAs in some countries must submit requests for access for some asset types, causing delays and reducing the possibility of early detection of corruption or money laundering. The most common asset types where a formal request is required are watercraft and aircraft, which in some cases have several subsidiary registers (for example, for different types of craft). Additionally, Irish LEAs must currently submit a request via email for beneficial ownership information of “certain financial vehicles”, referring to investment fund structures.

The challenges are not limited to legal and policy frameworks. Our research shows that barriers such as lack of access to machine-readable and bulk datasets also hinder investigators from using the information effectively, even in countries where access to information is possible. Lack of access to machine-readable data and bulk datasets limits competent authorities’ ability to conduct the types of large-scale data analysis essential to efficient detection of suspicious cases or patterns.

Bulk access to ownership data, whether through the ability to download the complete register dataset (or select a tailored subset of the dataset, such as all companies registered in the last six months) or via an application programming interface (API), is rare across the assessed EU countries. Italy’s Guardia di Finanza (financial police) has access to bulk data sets from several registers, including legal entities, bank accounts, land and real estate, and motor vehicles. Aside from Italy, authorities have access to bulk data sets only in a few exceptional cases: data on land and real estate owned by legal entities in Germany, or motor vehicle in Lithuania and Ireland.

Access to machine-readable data by FIUs and LEAs varied widely across countries and across asset type. Surveys of the authorities indicated that more countries have access to machine readable data from the register of beneficial owners, the register of legal entities, and the bank account register than they do from registers of other types of assets.

Commercial data service providers and journalists often have better ownership databases than authorities. As a result, many LEAs and FIUs are compelled to rely on expensive commercial databases to support their work.

Once they have it, what authorities are legally empowered to do with ownership data is often limited. In most countries assessed, LEAs are only permitted to consult registers when working on a designated case – except for data that are fully public sources, such as legal entity registers. As a result, they often cannot use data for proactive investigations, which involve systematically analysing ownership and financial information to detect suspicious patterns and red flags, uncover hidden networks, or identify potential risks before a case is formally opened.

Limitations on use of ownership information, in particular laws and policies that restrict authorities to ongoing cases, severely hamper the ability of law enforcement to uncover complex financial crime schemes at an early stage, shifting their work toward reactive enforcement after schemes are much more advanced.

French LEAs highlighted that the legal framework limits the possibility of cross-referencing data from separate ongoing investigations, while a lack of software tools further limits data processing and analysis.

Italy stands out among the reviewed countries: the Guardia di Finanza can use its bulk access to legal entities, land and real estate and motor vehicle data to proactively identify suspicious patterns and red flags that can trigger investigations.

Corruption investigations hinge on meaningful access and effective use of ownership data. In the EU the data generally exists – but it is not interconnected, not in the right format, and often not provided at the speed or scale investigators need, both within countries and among member states.

As a result, investigators lose time chasing information across systems and are sometimes unable to obtain it. The absence of advanced data analysis tools makes it harder to connect the dots. And, some key types of assets, such as crypto-assets, may remain hidden from investigations.

Steps should be taken now to improve authorities’ effective use and access to ownership information:

Effective access. Countries should ensure that authorities have streamlined access to beneficial ownership data on legal entities and arrangements as well as to asset ownership data. This should be prescribed in legislation. Given that authorities have limited resources, access to bulk data from registers would help authorities detect ‘unknown unknowns’: patterns, anomalies and red flags that emerge only through broader analysis. Register authorities, for their part, should accept feedback and work to continuously improve ease of access.

Law enforcement agencies we interviewed broadly support greater centralisation and interconnection of registers, or even a comprehensive EU-wide asset register, citing potential for investigative efficiency. Proposals for an EU-wide asset register already exist, and a feasibility study has been conducted, but the European Parliament’s consideration of this measure under AMLD6 was derailed by the 2022 ruling by the EU Court of Justice restricting public access to beneficial ownership registers, which demanded co-legislators’ focus elsewhere. This conversation must continue.

Privacy and data protection. Clear, public guidance from EU and national data protection authorities is needed on what and how ownership data can be shared and analysed for corruption and money laundering investigations. Authorities we interviewed pointed out that currently, privacy restrictions are inconsistently interpreted across jurisdictions. EU-level protocols would bring consistency when member states apply narrower interpretations that hinder investigations or early detection of corruption and money laundering. As in counterterrorism, privacy and security are already weighed against one another. A similar dialogue is needed on how frameworks should adapt to better balance data protection with proactive anti-corruption and anti-money laundering work.

Training and technology. Authorities should be adequately resourced to offer ongoing training. Staff need both foundational and advanced skills in data analysis, crypto-related investigations and IT forensics for routine use of ownership data. Beyond training, they also require cutting-edge tools: harmonised IT systems, cross-referencing software, automated red-flagging systems, and platforms to connect ownership data across asset types and jurisdictions.

Authorities cannot detect and uncover all corruption-related crimes alone. Civil society organisations and investigative journalists play a crucial role in uncovering corruption-related money laundering. While public access to beneficial ownership information remains the gold standard, in the majority of the EU countries access to this data is – or will be – restricted to journalists, civil society organisations and academics whose work is connected to anti-money laundering or related crimes. Providing civil society and public watchdogs with broad access to wide-ranging data, such as access to asset ownership data, especially in bulk, can allow them to analyse information, discover schemes, uncover patterns and trends, and alert authorities.

Stay tuned for our full report on authorities’ resources, capacities and needs coming in October.