## 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](https://www.imf.org/en/publications/wp/issues/2025/09/12/targeted-transparency-sectoral-approach-to-beneficial-ownership-in-procurement-and-real-570051)

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## Bibliographic details
- 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

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### 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.
- 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.

### Major findings and observations
- 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.

### Policy recommendations and design considerations
- 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).

### Sector examples and operational lessons
- 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.

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_Source: https://www.imf.org/en/publications/wp/issues/2025/09/12/targeted-transparency-sectoral-approach-to-beneficial-ownership-in-procurement-and-real-570051_