The UK has not been blind to the risks outlined in the previous article. In response to mounting evidence, successive governments introduced registers, disclosure requirements and expanded AML obligations. On paper, transparency improved. In practice, the picture is more complicated.

Registers and reforms

In the wake of the Panama Papers and Russia’s invasion of Ukraine, the UK moved decisively, at least on paper, to confront opaque ownership in its property market. The introduction of the Register of Overseas Entities under the Economic Crime (Transparency and Enforcement) Act 2022 represented a clear acknowledgement that anonymous property ownership posed systemic economic crime risks.

This reform sat alongside earlier and parallel measures: the extension of the Money Laundering Regulations to estate and letting agents, HMRC supervision, the use of Unexplained Wealth Orders, and the formal classification of property as a risk sector within the UK’s National Risk Assessment. Taken together, these measures marked a significant expansion of the UK’s legal and regulatory framework.

Yet despite this expanding framework, the underlying problem has not receded.

The reality

Analysis of Land Registry and Companies House data shows that tens of thousands of UK properties remain effectively anonymous, notwithstanding new disclosure requirements. Transparency International UK has found that nearly 52,000 properties in England and Wales in 2023 were still owned through structures that obscure the real human owner, even after the transparency reforms came into force.^[1]Nearly 52,000 UK properties still owned anonymously – despite new transparency law | Transparency International UK In many cases, overseas entities have failed to register at all; in others, they have listed corporate entities, trusts, or claims of “no beneficial owner” in ways that technically comply with form requirements while defeating their purpose.

The scale of overseas ownership itself is now well documented. Updated analysis published in January 2026. drawing on Land Registry and Companies House data estimates that nearly 100,000 properties in England and Wales, worth approximately £460 billion, are owned by offshore companies.^[2]Analysis published by Tax Policy Associates in January 2026, drawing on Land Registry and Companies House data. Who secretly owns Britain? Map of hidden UK property owners. An accompanying interactive map, echoing the 2015 Private Eye investigation, demonstrates the geographic spread of these holdings, from prime central London to regional towns far from traditional financial centres.

The most striking finding, however, is not simply the volume of offshore ownership, but the persistent failure to identify real human owners behind it. According to the analysis, in around 44% of cases, representing approximately £190 billion of property, the beneficial owner remains hidden despite legal requirements introduced in 2022. Some companies have failed to register altogether. Others list offshore corporate entities as beneficial owners in place of individuals. A significant proportion rely on trust structures that continue to obscure ultimate control.

In practice, this opacity is rarely the result of a single layer, but of multiple layers of ownership that progressively distance property from its ultimate controller.

This opacity is not benign. Transparency International UK has previously identified over £6.7 billion worth of UK property purchased with suspect wealth, including £1.5 billion linked to Russian individuals either sanctioned, connected to the Kremlin, or both.^[3]Stats reveal extent of suspect wealth in UK property and Britain’s role as global money laundering hub | Transparency International UK

What has changed since Private Eye first mapped offshore owned property in 2015 is not the scale of the issue, but its visibility. Today, the data is richer, more official, and more difficult to dismiss. But visibility has limits.

Limits of visibility

Registers depend heavily on self‑reporting, and criminals do not self‑identify. Where enforcement is slow, sanctions weak, or verification minimal, opacity persists not because it is inevitable, but because it remains tolerable. The result is a system in which legitimate owners comply, while high risk actors exploit gaps, delays, and complexity.

The data itself also has practical constraints. Land Registry records reflect legal ownership, not control. They cannot account for informal influence, nominee arrangements, or layered trusts spanning multiple jurisdictions. Nor do they capture properties held through UK‑registered companies whose ultimate controllers sit offshore, a route that remains entirely outside the overseas ownership dataset. In this sense, current figures almost certainly understate the true level of opaque ownership, rather than exaggerate it.

Crucially, even where opacity is identified, consequences remain inconsistent. Failures to register or to provide accurate beneficial ownership information have, in many cases, resulted in little more than delayed filings or nominal penalties. The signal to high‑risk actors is ambiguous at best.

Overseas ownership is not inherently problematic. Many offshore structures exist for legitimate commercial or personal reasons. The risk arises when opacity becomes normalised and when anonymity is treated as a feature rather than a red flag. In such an environment, property becomes an attractive repository for illicit wealth precisely because visibility is partial, delayed, and weakly enforced.

Taken together, the data reinforces a recurring theme in the UK’s response to property‑linked economic crime. Transparency has improved, but visibility remains incomplete. Maps and registers can show where risk may lie. They cannot, on their own, prevent suspect capital from entering the housing market or ensure meaningful challenge at the point of transaction.

And therein lies the rub – the money still flows in. We may have a better idea of who may own it but the cash still flows through our financial architecture in a seemingly unchecked manner.

The core issue

The Private Eye map still holds over a decade later. The warning is no longer speculative, leaked, or informal. It is embedded in official datasets, regulator reports, and enforcement statistics. The UK no longer lacks evidence.

What remains unresolved is whether transparency will be backed by the verification, supervision, and deterrence necessary to stop suspect money entering the housing stock in the first place. Until that gap is closed, UK property will remain visible, but vulnerable.

The uncomfortable reality is that criminals do not need perfect anonymity, only sufficient opacity. As long as overseas company structures can continue to acquire and hold UK property without timely, verified, and enforceable disclosure of real ownership, the gap between what the UK can see and what it can stop will stubbornly persist.

To understand how these vulnerabilities play out in practice, it is necessary to move beyond ownership structures and examine how different segments of the property market are actually used and misused. The next article explores these risks across the real estate ecosystem, from prime property to lettings and commercial assets.

About the authors

Priya Giuliani is a specialist in financial crime investigations and compliance, with 30 years’ experience, including a decade as a Partner. She advises clients proactively on assessing and managing financial crime risk, with a focus on governance, oversight, conduct, and the training of Senior Managers and Boards.

Her investigative experience provides deep insight into how financial crime, such as money laundering, terrorist and proliferation financing, sanctions breaches, tax evasion, bribery, corruption, and fraud, can occur, including through the use of professional enablers. She is highly experienced in designing and evaluating the control frameworks required to manage these risks effectively. Priya has also been appointed on numerous Skilled Person engagements.

Widely regarded as a highly experienced and well-qualified expert in financial crime risk management and investigations, she works closely with clients to develop proportionate and effective control frameworks.

Priya has led dozens of investigations alongside law enforcement agencies into the laundering of proceeds of crime derived from drug trafficking, human trafficking, and carousel fraud through UK and international property markets. She has also investigated how property investment and lettings companies, particularly those with large portfolios of low value, high volume housing stock, have been used to generate funds to support terrorist activity.

Leanard Phillip is a senior governance and financial crime compliance specialist, MLRO, and regulatory adviser with extensive experience across the banking, UK real estate, and fintech sectors. He is the Founder and Executive Director of Optimum Compliance Consultancy Limited and has advised firms on anti-money laundering (AML), counter-terrorist financing (CTF), sanctions compliance, regulatory risk management, and governance frameworks.

Leanard has held senior financial crime leadership roles within major international organisations, including responsibility for AML and sanctions oversight within the UK property sector. He has also led and supported a number of Financial Services and Markets Act (FSMA) skilled person reviews, remediation programmes, and financial crime transformation projects across financial institutions within the City of London.

He is particularly recognised for his recent work on financial crime risk within real estate, including sanctions exposure, beneficial ownership transparency, unexplained wealth orders, and the misuse of UK property for money laundering and organised crime. Leanard regularly contributes to industry discussions on economic crime, regulatory reform, and the intersection between illicit finance and wider social and economic harm.

In addition to his advisory work, Leanard serves as a mentor, trainer, and speaker on AML, sanctions, and financial crime compliance matters both in the UK and internationally.

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