From real estate to yachts: What do we know about assets across the EU?

In the French town of Sciez, near the majestic Lake Geneva, stands an exclusive villa whose ownership was, for some time, concealed behind Sigmateli Limited – a company registered in Cyprus. Moldovan and French authorities have linked the property to Vladimir Plahotniuc, the exiled business tycoon, former parliamentarian and one-time leader of Moldova’s Democratic Party. He is believed to be one of the key beneficiaries of the infamous “Theft of the Century”, a staggering US$1 billion fraud case that drained nearly one-eighth of Moldova’s gross domestic product. Despite Sigmateli Limited dissociating itself from Plahotniuc, recently the French supreme court upheld an earlier ruling to seize the property.

More often than not, however, authorities hit a dead end when investigating suspicious properties.

High-value assets such as real estate, yachts and luxury vehicles are often favoured by corrupt and criminal actors seeking to enjoy the spoils of their illicit gains. Other vehicles – including alternative investment funds and crypto accounts – can also be used to launder and stash dirty money abroad. Ownership of these assets is often difficult to ascertain, especially when obscured through anonymous companies and trusts. When held across borders through offshore companies, the risk of concealed wealth rises – making potential corruption and money laundering even harder to uncover.

To address this issue, greater transparency in asset ownership is crucial. This includes ensuring that information on both the assets and their ultimate – or beneficial – owners is accessible.

To assess the current state of ownership transparency in the EU, Transparency International has examined the availability of information on various vehicles and asset classes across nine countries as part of the Strengthened Enforcement Capacities of Public Authorities (STEP EU) project. We analysed the disclosure requirements for asset classes commonly linked to past corruption and money laundering cases or those posing a particular risk: bank accounts, real estate, motor vehicles, watercraft, aircraft, crypto accounts and collective investment undertakings. We also reviewed the registers of beneficial owners for legal entities – such as companies and partnerships – as well as legal arrangements – like trusts, which are commonly used to hold assets.

We found that while information on certain assets such as real estate and motor vehicles is registered across the board, others like crypto assets are overlooked. And while most have made significant progress in setting up central registers with information on the beneficial owners of companies and trusts, certain types of investment funds and assets owned through foreign companies continue to be shielded from scrutiny.

Over the past decade, the EU has been gradually strengthening transparency requirements on the ownership of companies, trusts and assets – including through last year’s adoption of an ambitious anti-money laundering legislative package.

The 6th Anti-Money Laundering Directive (AMLD6) and the Anti-Money Laundering Regulation (AMLR), once transposed into member states’ national laws and adequately implemented, will increase transparency across key asset classes. This includes new rules that expand beneficial ownership reporting requirements, create new reporting obligations for crypto asset accounts and enhance authorities’ access to data across certain asset classes – including motor vehicles and watercraft.

In order for authorities to prevent, detect and investigate cases of assets being purchased with dirty money, they must first be aware of these assets.

Our findings reveal that while countries have established and operate registers for major asset categories, most asset registers include basic details about the owner and the asset itself, such as a unique identifier, usage type (commercial or private) and technical specifications.

However, significant gaps remain regarding transaction data. While real estate prices are accessible through supporting documents in all countries, this level of transparency is generally absent for other asset types like motor vehicles, watercraft and aircraft. In only a few instances, such as Italy's motor vehicle register, is the transaction price recorded – and in this case, it is even structured as historical data within the register itself, not merely as scanned supporting documents.

As for ownership, asset registers typically only record the immediate title holder. If the asset is directly owned, the registers list the name of the individual person. However, if it is held through a company or a trust, usually only the name of that company or trust is recorded. Revealing the real owner behind these structures requires one of two approaches: (a) the direct inclusion of beneficial ownership information within the asset register, or (b) cross-referencing data between asset registers and beneficial ownership registers for legal entities and arrangements.

This type of cross-referencing is often impeded by the design of asset registers – their structure, the scope of data they contain and their level of digitalisation.

A robust and effective framework must also allow authorities and other watchdogs to identify the real owners of legal entities and arrangements, as they often obscure the ownership of assets like bank accounts or real estate. While most member states have established and maintained central beneficial ownership registers for legal entities and arrangements as required by EU directives since 2015, there are differences in their set-up and ease of access.

Latvia stands out as an example of good practice. It incorporates beneficial ownership information of legal entities and arrangements into its company register, which includes details on companies’ board members, articles of association and annual accounts. Crucially, this provides detailed information on companies, displaying the full chain of ownership along with key identifiers like date of birth and passport or ID numbers, allowing for clear and unambiguous identification of beneficial owners.

The Italian beneficial ownership register, by contrast, remains suspended and non-operational due to an ongoing legal challenge since December 2023. In October 2024, the Council of State – Italy’s highest administrative court – referred the case to the EU Court of Justice (CJEU). The dispute centres on the definition of “legitimate interest,” the scope of “legal arrangements,” and whether national rules align with EU law. Until the CJEU reaches a decision, the entire register will remain suspended.

Until now, the use of foreign legal entities to purchase assets in the EU created something of a black box. Our 2023 study with Transparency International France and the Anti-Corruption Data Collective revealed widespread anonymous ownership of real estate in France through subsidiaries of foreign companies, with only a small fraction of properties traceable to a real person. The study also found that 71 per cent of corporate-owned real estate in France is held anonymously. The proportion of properties owned by foreign entities may be even higher to obscure ownership of assets.

To address this, the new EU anti-money laundering legislation requires that foreign legal entities and arrangements registered or administered outside the EU – and which have acquired real estate in EU countries since 2014 – must submit their beneficial ownership details to the central beneficial ownership register. Germany and Latvia already require this, while other member states must implement these measures by July 2027.

Even more overlooked are movable assets such as luxury cars, yachts and private jets. Like real estate, the new EU anti-money laundering legislation introduces reporting requirements aimed at addressing cases where high-value assets in the EU are owned through foreign legal entities or arrangements. This applies to non-commercial motor vehicles valued at €250,000 or more, as well as non-commercial watercraft and aircraft priced at €7.5 million or higher. None of the nine member states we assessed currently have such measures in place, and all must act to implement these provisions by July 2027.

While many EU member states have made strong progress on digitalisation – some even surpassing AMLD6 requirements by storing information in asset registers in machine-readable format – critical gaps remain.

In Ireland, for example, watercraft registers are still paper-based. The same is true for some local watercraft registers in Germany, although gradual improvements are being made as more registers are digitised and centralised in the Hamburg port hub. Aircraft registers in both Germany and Portugal also remain non-digital.

However, digitalisation alone isn’t enough. Linking data effectively depends on the use of unique identifiers – such as tax numbers or passport IDs – that clearly distinguish individuals or entities. Without these, it’s difficult to determine who truly owns an asset.

Italy, Latvia, Lithuania, Portugal, Slovenia and Spain require unique identifiers for both legal entities and individuals across all relevant registers. At the other end of the spectrum, Germany lacks a comprehensive identifier system. While legal entities receive a unique ID within the commercial register, no standard identifier is used across registers for either individuals or legal entities, limiting the ability to match data. France similarly does not systematically record unique identifiers for individuals across its registers. This fragmented approach complicates efforts to trace ownership across borders.

Spain stands out as a model of good practice, requiring the use of European Unique Identifiers in its beneficial ownership, company, and real estate registers – helping to align national systems more closely with EU-wide frameworks.

To prevent, detect and investigate potential flows of corrupt money into their economies, authorities must first have access to information on asset ownership. Requiring the registration of assets is the critical first step. Next, they must ensure an adequate data ecosystem that enables the tracking of ownership for suspicious assets. Finally, it is vital that authorities can easily access and use this data for their investigations – a key area we will be assessing in the coming months.

Our analysis of available asset information in the sample of nine EU countries shows a solid foundation for greater ownership transparency, but significant gaps remain. In eight out of the nine countries, public authorities do not maintain any registers or records of crypto asset account holders. In seven out of the nine countries, foreign legal entities are not required to report their beneficial owners when acquiring real estate – and none of the countries impose this requirement for other high-value assets.

Additionally, none of the assessed countries mandate comprehensive disclosure of all end-investors in collective investment undertakings, while current beneficial ownership reporting requirements still allow considerable room for circumvention.

The new AMLD6 and the AMLR contain important advances for stronger asset ownership transparency. It is crucial that member states transpose and implement these rules in a timely and effective manner. Governments should consider early adoption of these measures to close critical loopholes – particularly those enabling anonymous ownership of real estate and other assets through foreign companies and trusts, a key vulnerability that requires particular attention from policymakers.

Specific risks unique to each country demand that they go beyond the minimum standards set by EU rules. Countries with significant crypto sectors, for instance, should strengthen disclosure obligations for digital assets, while those with large investment fund industries must urgently enhance transparency around beneficial ownership for end-investors. Addressing these gaps is essential for disrupting the pathways used to hide illicit wealth.

Transparency International has been working on a two-year project to combat cross-border corruption and financial crime. The project, Strengthened enforcement capacities of public authorities (STEP EU), is funded by the European Union and is undertaken in cooperation with Brussels-based Transparency International EU and national chapters in France, Germany, Ireland, Italy, Latvia, Lithuania, Portugal, Slovenia and Spain.