Targeted Transparency: Sectoral Approach to Beneficial Ownership in Procurement and Real Estate

IMF Working Papers, September 12, 2025

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Canonical URL: Targeted Transparency: Sectoral Approach to Beneficial Ownership in Procurement and Real Estate

Authors: Ivana Rossi, Chady A El Khoury, Indulekha Thomas, Luisa Malcherek, Mohammed Al Janahi
Published: September 12, 2025
Series: IMF Working Papers
DOI: https://doi.org/10.5089/9798229023832.001

Identifying the natural person who ultimately owns or controls an asset—known as the beneficial owner—is a key transparency measure to prevent misuse for criminal or unethical purposes.
High-risk sectors face amplified vulnerabilities during economic or existential crises, such as financial bubbles or climate change.
Many countries are establishing centralized beneficial ownership registries—often linked to commercial registers for anti-money laundering/combating the financing of terrorism (AML/CFT) compliance—but these may not fully meet the needs of sector-specific oversight.
A sectoral approach aligns data collection and use with the unique risks and operational realities of each sector and complements national beneficial ownership frameworks.
Flexible implementation can range from basic disclosures in transactions to advanced verification, while minimizing compliance burdens and considering sectoral capacity.
Experience from the COVID-19 pandemic shows beneficial ownership transparency in procurement helped mitigate corruption risks; the approach is being explored for other high-risk areas such as real estate, which is particularly vulnerable to money laundering.

Centralized beneficial ownership registries do not always provide the granular, tailored data required by sectoral authorities such as procurement authorities or land registries.
Sectoral authorities may require:
- information on foreign entities,
- lower thresholds for politically exposed persons (PEPs),
- more granular or tailored beneficial ownership data for operational oversight.
Sectoral approaches can address gaps by:
- aligning data collection with sector-specific risks,
- enabling flexible implementation from basic disclosures to advanced verification,
- complementing national frameworks rather than replacing them.
Real estate is highlighted as a high-risk sector for money laundering that could benefit from targeted transparency measures.

Design should:
- consider sectoral capacity,
- minimize compliance burdens,
- allow for flexible implementation calibrated to sector risks and operational realities.
Sectoral disclosure regimes should be coordinated with national beneficial ownership frameworks to ensure complementarity and avoid duplication.
Tailoring can include sector-specific thresholds, verification standards, and data elements (for example, foreign ownership details or PEP thresholds).

Procurement:
- Beneficial ownership transparency during the COVID-19 pandemic helped mitigate corruption risks in procurement.
Real estate:
- Identified as particularly vulnerable to money laundering and a priority for exploration of sectoral beneficial ownership transparency.