Author
Margot Mollat
Date of publication
27 November 2025
Reading Time
4 minutes

Since the Panama Papers exposed the global offshore system in 2016, there has been mounting scrutiny over how shell companies and complex corporate structures are used to divert public funds, launder money and avoid taxes. The UK and its network of Overseas Territories sit at the centre of this shadow system which allows billions to be siphoned away each year.

Our research at Transparency International UK has found that companies registered in UK Overseas Territories have been used in more than 273 cases of large-scale corruption and money laundering, amounting to £250 billion across 79 countries. The British Virgin Islands alone featured in 92 per cent of these cases. Almost £6 billion of this money was used to purchase UK properties through these shell companies.

Following the Sanctions and Anti-Money Laundering Act (2018), UK Overseas Territories committed to establishing public registers of beneficial ownership – registers that would reveal the true owners of companies. After a 2022 European court ruling on privacy rights many territories scaled back to ‘legitimate interest’ models, where only certain groups focused on uncovering money laundering, would have access. At the November 2024 Joint Ministerial Council, territories committed to implementing these registers ‘with the maximum possible degree of access and transparency’.

Today, we're publishing our assessment of how successfully Bermuda, the British Virgin Islands, Cayman Islands and Montserrat have delivered on their commitments. The findings are deeply concerning; behind the promise of progress, very little has changed for most of them.

Opening Up Offshore Secrecy scores these territories across 92 criteria covering both the quality of their beneficial ownership frameworks and accessibility to key data. While Montserrat achieved an 'A' grade in both categories, BVI and Bermuda both received failing grades ('F') for accessibility. The territories that opted for legitimate interest models are implementing them in ways that fall far short of EU standards, severely limiting the ability of journalists, civil society and law enforcement to combat money laundering.

The problems are stark. Both BVI and Bermuda still don’t have legitimate interest access registers in place, with those not expected to be live until 2026 - a huge delay to their commitment to end corporate secrecy on their shores. 

In BVI, proposed tipping-off provisions would alert criminals they're under investigation, while in Cayman, despite having launched its register, applications are assessed case-by-case with high evidentiary thresholds and cumbersome processes requiring international bank transfers. Most critically, searches can only be conducted by company name, not by beneficial owner – meaning you must already know what you're looking for. 

In Bermuda, the current legislation and framework haven’t been written, meaning there is a lack of clarity over how access will be assessed and no clear protection for users' identities.

When billions are looted and laundered through these jurisdictions, communities worldwide pay the price in schools, housing and hospitals desperately needing public funding. 

The case studies in our report illustrate this: Ukrainian oligarchs used BVI shell companies to steal approximately $1.9 billion from PrivatBank, Ukraine's largest financial institution. Brazilian firm Odebrecht used BVI companies to funnel $788 million in bribes across 12 countries. Cayman Islands entities played a central role in the 1MDB scandal, one of the largest corruption cases in history.

Journalists, civil society groups and investigators are essential to exposing this wrongdoing – especially in jurisdictions where law enforcement may be overly stretched and underfunded. Denying them meaningful access sends a clear message: these territories still prioritise secrecy over efforts to tackle money laundering.

But it’s not all bad news. Montserrat demonstrates what's possible. The territory has established a fully public register that is online, centralised and free to access. Gibraltar and St Helena have done the same, proving greater transparency is achievable.

Public access remains the most straightforward and cost-effective approach. It ensures appropriate users can access data while maintaining quality – public disclosure creates natural deterrents and encourages self-policing. Widespread access means more users can identify and challenge inaccuracies.

Where registers serve a narrower purpose, legitimate interest models can still play a role – but they ae significantly more complex and resource-intensive. They require territories to define broad, inclusive categories of users who can access and utilise data without undue restrictions. Without this, such registers risk falling short of their objectives.

Seven years after Parliament called for public registers, the major offshore financial centres have missed commitments, deadlines and milestones. This raises serious concerns about their willingness to deliver meaningful transparency.

As the UK prepares to host an international summit on illicit finance, meaningful access to beneficial ownership registers cannot be optional. Without decisive action, illicit wealth will continue flowing through the UK's backdoor, enabling organised crime groups and kleptocrats to conceal assets, evade sanctions and undermine the UK economy.

Seven years is long enough. It's time for UK Overseas Territories to deliver on their transparency commitments – in full and without further delay.

Further reading