The Register That Changed Everything: How UK Property Transparency Finally Became Reality
The Economic Crime Act 2022 and the End of Anonymous Property Ownership
On August 1, 2022, a fundamental shift occurred in UK property law. For the first time in British history, overseas entities owning UK property were required to publicly disclose their beneficial owners through the new Register of Overseas Entities (ROE).
The timing was no coincidence. As Russian forces invaded Ukraine in February 2022, public attention focused intensely on how oligarchs and other corrupt actors had used anonymous property ownership to launder money through London's luxury real estate market.
The Anonymous Property Problem
For decades, the UK had inadvertently become a global hub for anonymous property investment. Overseas companies could purchase British real estate without revealing who actually owned or controlled them. This system, while legal, created an ideal environment for money laundering.
Research by Transparency International UK had consistently highlighted this vulnerability. Their studies showed that properties worth billions of pounds were held through complex offshore structures, making it impossible for law enforcement to identify the true beneficial owners.
The scale of the problem became clear through high-profile cases. Properties in prime London locations—Belgravia, Knightsbridge, Mayfair—were owned by shell companies registered in jurisdictions with strict secrecy laws. When these properties were linked to corruption scandals or sanctions targets, investigators often found themselves unable to identify the real owners.
The Legislative Response
The Economic Crime (Transparency and Enforcement) Act 2022 was the government's response to mounting pressure for action on economic crime, particularly following Russia's invasion of Ukraine. The Act created the Register of Overseas Entities, administered by Companies House.
Under the new system, overseas entities that own or want to acquire property or land in the UK must:
- Register with Companies House
- Provide information about their beneficial owners
- Update this information annually
- Make this information publicly available
The register applies to overseas entities that have owned UK property since January 1999, creating a comprehensive historical record of ownership.
Early Implementation
The register's launch on August 1, 2022, marked a significant moment for transparency advocates. Within the first months of operation, thousands of overseas entities complied with the new requirements, revealing beneficial ownership information that had previously been hidden.
However, implementation has not been without challenges. Some entities have failed to register despite the legal requirement, while others have provided incomplete information. Companies House has had to develop new enforcement mechanisms to address non-compliance.
Real-World Impact
The register has already proved valuable in several ways:
Law Enforcement: The National Crime Agency and other law enforcement bodies now have access to beneficial ownership information that can support investigations into money laundering, sanctions evasion, and other economic crimes.
Academic Research: Researchers studying illicit finance flows have gained unprecedented access to data about property ownership patterns, enabling more sophisticated analysis of money laundering techniques.
Public Accountability: Journalists and civil society organizations can now identify the beneficial owners of high-value properties, supporting investigative reporting and advocacy work.
The Sanctions Connection
The register's importance became particularly evident following the imposition of sanctions on Russian oligarchs after the Ukraine invasion. Previously, sanctions enforcement was hampered by the difficulty of identifying which UK assets were actually controlled by sanctioned individuals.
The beneficial ownership information now available through the register has enabled more effective sanctions enforcement, though some cases remain complex due to sophisticated ownership structures designed to obscure true control.
Ongoing Challenges
Despite its achievements, the register faces several limitations:
Non-Compliance: Some overseas entities have simply failed to register, despite legal requirements. Enforcement action against non-compliant entities is ongoing but limited.
Information Quality: The accuracy of submitted information varies. While Companies House has powers to query suspicious filings, verification remains challenging.
Sophisticated Structures: The most determined actors continue to use complex legal arrangements that may technically comply with disclosure requirements while still obscuring beneficial ownership.
International Impact
The UK's register has influenced similar initiatives worldwide. The European Union is developing continent-wide beneficial ownership requirements, while several other jurisdictions have introduced comparable transparency measures.
This international trend suggests that the UK's approach, despite its limitations, represents a significant step toward global standards for property ownership transparency.
Looking Forward
The Register of Overseas Entities represents a fundamental shift from anonymous to transparent property ownership. While challenges remain in enforcement and verification, the register has established a new baseline for property transparency in the UK.
For anti-corruption advocates, the register demonstrates that technical reforms can achieve significant policy objectives. The system isn't perfect, but it has moved the UK from having virtually no transparency around overseas property ownership to having a comprehensive public database.
The real test of the register's effectiveness will come through its use in major investigations and prosecutions. As law enforcement agencies, journalists, and researchers continue to use the data, its value in combating economic crime will become clearer.
References
- UK Government. (2022). The new Register of Overseas Entities is live. GOV.UK. Available at: https://www.gov.uk/government/news/the-new-register-of-overseas-entities-is-live
- UK Government. (2025). Register of Overseas Entities. GOV.UK. Available at: https://www.gov.uk/government/collections/register-of-overseas-entities
- UK Government. (2023). Fact sheet: The Register of Overseas Entities (web accessible). GOV.UK. Available at: https://www.gov.uk/government/publications/economic-crime-transparency-and-enforcement-bill-2022-overarching-documents/factsheet-the-register-of-overseas-entities-web-accessible
- Companies House. (2022). Register of Overseas Entities – what, why and when. Companies House Blog. Available at: https://companieshouse.blog.gov.uk/2022/11/21/register-of-overseas-entities-what-why-and-when/
- UK Parliament. (2022). Economic Crime (Transparency and Enforcement) Act 2022. Available at: https://www.legislation.gov.uk/ukpga/2022/10/contents
- Farrer & Co. (2023). The Register of Overseas Entities: it's updating time! Available at: https://www.farrer.co.uk/news-and-insights/the-register-of-overseas-entities-its-updating-time/
- Library of Congress. (2022). United Kingdom: Government Introduces Register of Overseas Entities to Increase Transparency and Fight Economic Crime. Available at: https://www.loc.gov/item/global-legal-monitor/2022-11-29/united-kingdom-government-introduces-register-of-overseas-entities-to-increase-transparency-and-fight-economic-crime/
