IMF-有针对性的透明度：采购和房地产受益所有权的部门方法（英）

Targeted Transparency: Sectoral Approach to Beneficial Ownership in Procurement and Real Estate Ivana Rossi, Chady El Khoury, Indulekha Thomas, Luisa Malcherek, Mohammed Janahi WP/25/181IMF 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. 2025 SEP © 2025 International Monetary Fund WP/25/181IMF Working Paper Legal Department Targeted Transparency: Sectoral Approach to Beneficial Ownership in Procurement and Real Estate Prepared by Ivana Rossi, Chady El Khoury, Indulekha Thomas, Luisa Malcherek, Mohammed Al Janahi* Authorized for distribution by Brian Patterson 2025 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. ABSTRACT: 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. RECOMMENDED CITATION: Rossi, Ivana, El Khoury, Chady, Thomas, Indulekha, Malcherek, Luisa, Janahi, Mohammed. 2024. “Beneficial ownership transparency in high-risk sectors.” IMF Working Paper No. 25/181. International Monetary Fund. Washington D.C. * The authors thank Brian Patterson, Richard Berkhout, Kathleen Kao, Pierre Bardin