IMF Working Papers

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

ByIvana Rossi, Chady A El Khoury, Indulekha Thomas, Luisa Malcherek, Mohammed Al Janahi

September 12, 2025

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Format: Chicago

Ivana Rossi, Chady A El Khoury, Indulekha Thomas, Luisa Malcherek, and Mohammed Al Janahi. "Targeted Transparency: Sectoral Approach to Beneficial Ownership in Procurement and Real Estate", IMF Working Papers 2025, 181 (2025), accessed 12/5/2025, https://doi.org/10.5089/9798229023832.001

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Disclaimer: IMF Working Papers describe research in progress by the author(s) and are published to elicit comments and to encourage debate. The views expressed in IMF Working Papers are those of the author(s) and do not necessarily represent the views of the IMF, its Executive Board, or IMF management.

Summary

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. This is especially critical in high-risk sectors, where vulnerabilities are amplified during economic or existential crises, such as financial bubbles or climate change. While 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—these may not fully meet the needs of sector-specific oversight. Agencies like procurement authorities or land registries often require more granular or tailored beneficial ownership data, such as information on foreign entities or lower thresholds for politically exposed persons (PEPs). A sectoral approach to beneficial ownership transparency addresses these gaps by aligning data collection and use with the unique risks and operational realities of each sector. This allows for flexible implementation—from basic disclosures in transactions to advanced verification—while complementing national beneficial ownership frameworks. Importantly, the design should consider sectoral capacity and minimize compliance burdens. Drawing on lessons from the COVID-19 pandemic, where beneficial ownership transparency in procurement helped mitigate corruption risks, this approach is now being explored for other high-risk areas such as real estate, which is particularly vulnerable to money laundering.

Subject: Anti-money laundering and combating the financing of terrorism (AML/CFT), Civil society, Corruption, COVID-19, Crime, Economic sectors, Health

Keywords: Anti-money laundering, Anti-money laundering and combating the financing of terrorism (AML/CFT), beneficial ownership, Civil society, Corruption, COVID-19, Global, IMF working paper No. 25/181, industries transparency initiative standard, land registry, ownership registry, ownership transparency, procurement, real estate, targeted transparency