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Case Study

Advocating for a Public Register of the Beneficial Owners of Overseas Companies that Own or Buy Property in the UK


The UK’s property market is a prime destination for the corrupt and other criminals to launder their stolen wealth. Using an anonymous shell company registered overseas, these individuals can purchase luxury property in the UK with the proceeds of their crimes, away from the prying eyes of journalists, politicians, law enforcement and the wider public. This enables them to enjoy their ill-gotten gains with impunity, and use vital UK housing as their own personal safety-deposit boxes.

To address this problem, the UK committed at the 2016 London Anti-Corruption Summit to introducing a public register of the beneficial owners of overseas companies that own or buy UK property.

By April 2018, the Government’s original deadline for tabling legislation for this register, the Government had responded to the results of its 2017 Call for Evidence on this policy. This response reiterated the Government’s commitment to publish a draft bill for this register in the Summer of 2019, with the aim of the register being operational in 2021. Although the register has not yet been legislated for, the Government has reiterated its commitment to deliver an operational register by 2021.


To keep pressure on the UK Government to deliver on its commitment to legislate for a property register and ensure the data in that register is accurate and verified, we:

  • Held meetings with key stakeholders and decision-makers, including in Parliament, Government, civil society and the private sector
  • Produced written briefings for Parliamentarians across the political spectrum
  • Co-produced with Global Witness a technical paper for the Department of Business, Energy and Industrial Strategy on reforms needed at Companies House to ensure company registration information is accurate and verified
  • Published blogs and social media content, and appeared in print and broadcast media
  • Made submissions to consultations in Government and Parliament
  • Built up our internal corruption case database, which underpins our relevant investigative and media work
  • Took part in Parliamentary evidence sessions, including with the Joint Select Committee on the Draft Registration of Overseas Entities Bill


In July 2018, the UK Government published – and opened a public consultation on – a draft bill for the property register, to which we submitted evidence. In February 2019, a joint parliamentary committee was appointed to scrutinise this draft bill.

In May 2019, the Government launched a consultation on proposals to reform Companies House[1], the body which will be responsible for the data submitted to the Registration of Overseas Entities Bill. This has been one of our key advocacy asks and will enable us to provide technical expertise to government on the means of verifying the accuracy of beneficial ownership data.

Subsequently, the Joint Committee on the Draft Registration of Overseas Entities Bill published its response to draft legislation for the property register[2], including a number of our key policy recommendations (for example, the verification of beneficial ownership data) in its report.

We have now published a joint manifesto against corruption with other leading anti-corruption NGOs in the UK (https://www.transparency.org.uk/publications/fighting-corruption-manifesto/), in which we are calling for all parties to commit to delivering this register of who really owns the overseas companies that hold UK property.


§  The production of reliable and technical content is an important action towards building trust with the government and effectively advocating for a commitment.

§  Furthermore, providing technical recommendations that can foster conversation and constructive feedback is a key step to maintaining pressure without falling into a lazy critique. Focusing on problems alienates stakeholders; providing informed solutions nurtures engagement.

§  To operate effectively in an extremely fraught political environment, we need to be extremely quick to react to opportunities when they arise – for example, where there are media stories relating to money laundering that we can link back to the need for a property register.

§  We have also had to learn to be flexible with our timelines, and take account of the current political climate.


[1] https://www.gov.uk/government/consultations/corporate-transparency-and-register-reform

[2] https://www.parliament.uk/business/committees/committees-a-z/joint-select/draft-registration-of-overseas-entities-bill/news-parliament-2015/report-publication/

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