Trust Issues: Tackling the final frontier in secret property ownership

As new transparency laws bed in, there are fewer places to hide who owns property in the UK. Yet while most homeowners' identities are easily accessible through public records for a nominal fee, a privileged minority continue to shield their assets behind elaborate legal structures known as trusts. These remarkable legal mechanisms – dating back to medieval crusades but still used to manage assets today – offer the wealthy and well-connected a powerful tool to maintain anonymity. New analysis by Transparency International UK now reveals for the first time the true extent of trust-based property ownership across England and Wales. 

Through open-source research we found over 170 properties, worth £2.5 billion, bought using suspicious wealth and owned via complex trust structures – 138 of these valued at more than £2.1 billion were bought in the last 15 years. These properties have ties to sanctioned individuals, politically exposed persons (PEPs) from high-corruption-risk countries, and individuals facing corruption-related charges or allegations. This could be the tip of the iceberg, with at least 236,500 properties across England and Wales owned by trust structures, worth at least £64 billion. 

For years, the UK’s property market has served as a safety deposit box for the corrupt and criminals looking to hide their dirty cash. Offshore companies had provided the perfect cover, allowing nefarious actors to own assets anonymously. These corporate shells, registered in secrecy jurisdictions, hid the identity of kleptocrats and oligarchs, making it nearly impossible for law enforcement, businesses and the public to trace the true owners. 

Using leaks and open-source material, NGOs and investigative journalists were able to lift this veil of secrecy periodically, exposing how corrupt elites exploited UK real estate to shield their wealth from scrutiny. We called for greater transparency over who owns these companies – a call welcomed in Whitehall, but not acted upon until 2022. 

Following Russia’s large-scale invasion of Ukraine, and with mounting pressure to tighten the net around Russian elites and their wealth, the UK Government introduced new laws requiring offshore companies owning properties here to disclose their ultimate owners. This reform appeared transformative on paper – a breakthrough for transparency advocates who had long campaigned for this change. But in practice, design flaws as well as existing weaknesses in our land ownership regime are allowing many to simply sidestep scrutiny by hiding behind trusts. 

Originally used by Norman knights to entrust their estates to stewards while they went to fight in the crusades, trusts have remained a feature of property ownership over the centuries. While differing slightly in form across jurisdictions, they tend to have at least three main elements: 

• settlor: the person giving property to the trust
• beneficiary: those benefiting from the trust
• trustee: someone holding the property on behalf of the beneficiary 

Unlike companies, trusts do not have their own legal personality. This means their bank accounts and property must be registered in the name of the trustee. While the trustee is given responsibility for controlling the asset, it is the beneficiary who ultimately benefits from it. In some cases, this could be those seeking a commercial and completely legal return through Real Estate Investment Trusts (REITs). Historically, others used trusts to avoid paying inheritance tax and stamp duty when transferring property, although these no longer have the same financial advantages they once had. However, for those looking to hide their ownership of assets, trusts provide an additional layer of secrecy. 

For example, when trusts own land directly, you will likely only see the name of the trustee and not the person who benefits from the property. Until recently, Britain lacked any public register of trusts, allowing those using these structures to hold assets anonymously. Even with the introduction of the Trust Registration Service, meaningful transparency remains elusive, as our investigation shows. The continued opacity provided by trusts has enabled some to invest suspect wealth into our economy, and skirt sanctions. 

Since 2016, we have collected information on suspect funds being invested into UK property. We have documented over 170 properties worth £2.5 billion – purchased using a trust structure with concerning connections to illicit wealth – 138 of these valued at more than £2.1 billion were bought in the last 15 years. 

Drawing on leaked documents, court cases, our own investigations, and those by journalists and other civil society groups, we have uncovered several suspicious assets including:  

• A £61 million London apartment held through a trust arrangement whose owner was briefly revealed to be the partner of Russian oligarch Alexander Ponomarenko – the former owner of ‘Putin’s Palace’. The property does not have a Treasury freezing order against it, despite properties in France held by a similar arrangement being frozen.
• An £8.3 million London mansion ultimately held by a trust and linked to a sanctioned Putin ally, Igor Komarov, that had not been identified as frozen by UK authorities.
• £130 million worth of UK property, first uncovered by the Organized Crime and Corruption Reporting Project, owned by Azerbaijan’s first family, the Aliyevs, and their associates.
• £40 million of central London commercial property held by a company controlled by a trustee who is a member of a Singaporean money laundering gang serving time in jail.
• £55 million worth of commercial property owned by the former Malaysian Finance Minister via trusts . He died before a criminal trial into his wealth could take place. 

These are just a few examples of trusts enabling suspect wealth to enter the UK market unchallenged. And as a recent report from the UK Government shows, trusts are also likely hampering the effectiveness of the UK’s sanctions regime. 

Over the past decade, the UK has made slow but steady progress in increasing transparency over those owning land indirectly via companies. 

In 2016, the people with significant control (PSC) register began disclosing to the public those controlling UK companies, including those holding property assets. Six years later in 2022, following years of delays, Parliament extended these disclosure requirements to offshore companies holding property here – known as the Register of Overseas Entities (ROE).  

While the PSC and ROE are already bearing fruit, revealing politically-linked and sanctioned owners of UK land, design flaws in the law mean they can be circumvented easily using trust arrangements in three key ways: 

• offshore companies controlled by trusts
• UK companies controlled by trusts
• direct ownership via trusts 

Our investigation reveals that, combined, these trust structures are being used to hide the owners of over 236,500 properties across England and Wales worth at least £64 billion. 

Offshore companies controlled by trusts  

Although offshore companies must disclose parties to trusts controlling them to Companies House under the ROE, Companies House does not currently have the right to publish this information. In practice, this means that if a kleptocrat holds land via an offshore company and wants to keep their assets a secret, all they have to do is insert a trust structure on top with them and/or their family as the beneficiaries. 

Through our data analysis, we identified over 5,500 overseas entities – almost one in six of all companies on the ROE – listing a trust in their ownership structure. Together, these companies own at least 23,000 properties in England and Wales worth over £17.5 billion. 

Following pressure during the passage of the Economic Crime and Corporate Transparency Act (ECCTA), the previous Government introduced an amendment to make trust information on the ROE available on application, and committed to consulting on how to improve the transparency of trust information more broadly. Although the new Government has yet to publish its response to the consultation, it has introduced regulations outlining how to apply for trust information on the ROE. Due to go live at the end of August 2025, this is a step in the right direction, but several issues remain. 

Under the regulations, applicants must name the trust about whose information they are seeking. However, this information is rarely known to journalists and investigators, and the names of trusts are not published on the ROE. Companies House may reject an application without this information. How this works in practice is yet to be seen, but there is a real risk that Companies House rejects 99 per cent of applications for information because of an overly cautious interpretation of the law. 

Those requesting access to information on more than one trust or relating to minors will also need to demonstrate they have a legitimate interest, defined as investigating money laundering, tax evasion, terrorist financing and/or sanctions evasion. How Companies House assesses these applications is also up in the air. Our initial reading is that this could be implemented in a way that would be more restrictive than the EU’s parallel approach under the Sixth Anti-Money Laundering Directive (AMLD6). In the EU, certain categories of journalists and NGOs will be presumed to have a legitimate interest rather than proving this on a case-by-case basis, as the UK ROE trust regulations require. 

Another unknown is how Companies House will use its power to impose conditions on how applicants use trust information. This could prevent journalists and NGOs from pursuing and publishing information in the public interest, and which are vital to the fight against economic crime. Again, this is policy Companies House will be working through before the system goes live. 

UK companies controlled by trusts

When properties are owned by UK companies that are controlled by trusts, transparency is even more limited. While offshore companies must at least collect and report trust information to Companies House (even if it remains largely unpublished), their UK-equivalents are subject to lesser requirements. 

UK companies who report a trust as their beneficial owner (PSC) only need to provide detail on the trustee. They are under no obligation to report their beneficiaries, settlors, or other trust parties to Companies House. Even if they did submit this information voluntarily, Companies House has neither the power nor obligation to publish it. 

This creates a perverse situation where trust-controlled UK companies are actually more opaque than some of their offshore counterparts. 

In total, we have found over 49,000 properties across England and Wales, worth at least £9 billion, held by UK companies controlled by a trust. 

Diagram 1: Examples of indirect trust ownership of property via UK and overseas companies 

Despite both UK and overseas companies now appearing on Companies House, we cannot access full ownership information when they are owned by trusts. 

Direct ownership via trusts 

The most fundamental challenge to property ownership transparency in Britain comes from real estate held directly by trusts without any corporate intermediary. In these cases, the beneficiaries remain almost entirely hidden from public view. Although HMRC manages the Trust Registration Service, which holds information about fiduciary structures directly owning property in the UK, this has proven largely ineffective in supporting investigations into potential money laundering.

HMRC collects information on the settlors, beneficiaries and trustees of overseas trusts that directly acquired property here on or after 6 October 2020, but it is currently not allowed to share this information with the public. This is despite the prevalence of this type of arrangement in large money laundering cases. Similarly, there are an array of other exemptions limiting the scope of what is accessible to the public.

HMRC does not hold data on trusts that acquired land prior to 2020. This creates a huge blind spot, with vast areas of land in the UK whose ownership remains obscured. Even the state does not know who owns many of these assets.

Additionally, even where it does hold information on UK-based trusts, the Trust Registration Service is of little use. Applicants can request this information by showing they have a legitimate interest. To prove this, they must demonstrate their involvement in investigating money laundering, and the information requested would advance an investigation. This is problematic for three reasons.

First, knowing the beneficial owner of a legal structure is invariably the start of an investigation, not something investigators obtain later on during their enquiries. The legal test puts the cart before the horse. In many instances, the information necessary for triggering suspicion is hidden behind a process that prevents those details being disclosed.

Second, HMRC can take eight weeks or more to process requests, with no meaningful feedback or appeal mechanisms for unsuccessful applicants. Given applications can fail for several reasons – including the information not being held, the trust being an overseas trust, and the trust not being identifiable – two months can pass only for investigators to end-up back where they started.

Finally, in the rare instance you do get a successful response, the data gives insufficient detail to be of use for investigating financial crime – merely confirming information you already knew via other sources.

Diagram 2: Example of direct trust ownership of UK property remaining hidden

To compound matters, not even the Government knows exactly how many properties are owned directly by trusts, as this information is not collected systematically by the land registries for England and Wales, Scotland and Northern Ireland. A ministerial response to a parliamentary question confirmed 56,000 trusts have notified the Trust Registration Service that their trustees had acquired a direct interest in UK land, yet this is not a complete picture given only trusts created after 6 October 2020 must register, and there is likely some level of non-compliance. Where data are available, they suggest the real figure could be much higher. 

Analysing commercial ownership records provided by the Land Registry for England and Wales, we found that at least 4,000 properties owned by 814 overseas companies with the words “trust” or “nominees” in their names – a common marker of direct trust ownership. When running the same analysis for the names of UK companies, we found over 105,000 additional properties owned this way by 4,688 legal entities. In total, this suggests there are at least 109,000 properties in England and Wales alone controlled by trusts, and these are only trusts involving a corporate trustee.  

Thanks to the UK’s archaic and fragmented land ownership system, the total figure for the whole country remains unknown. But using the Government’s figures and netting off those properties we suspected are held by corporate trustees, we calculate there are likely at least 164,500 properties owned directly by trusts in England and Wales. 

As information about companies becomes more transparent, there is a growing risk that those with wealth to hide move their assets into trusts – something we raised during the passage of the Economic Crime and Corporate Transparency Act.

The case of Maxim Bakiyev provides a case in point. The son of the former Kyrgyzstan President, Bakiyev was identified in a Global Witness investigation as having embezzled public funds, and sold off national energy companies for a fraction of their value. The investigation also revealed his involvement in a large-scale money laundering operation and the purchase of a £3.5 million mansion in Surrey, bought via a Belizean company.

In 2022, just as the new disclosure requirements for Overseas Entities kicked-in, the Surrey house was transferred to a trust administered by UK lawyers. In one of our few successful Trust Registration Service requests, HMRC confirmed Mr Bakiyev was the beneficiary of this trust.

Diagram 3: Maxim Bakiyev’s ownership of property via UK administered trust revealed

In England and Wales, disclosure of property ownership is convoluted and fragmented. Rather than providing meaningful information about the ultimate owner or beneficiary of property, the Land Registry provides details on the legal owner of the land – which could be an individual, but could equally be a UK company, an offshore business or a trustee acting on behalf of a trust. 

To identify a person behind these structures, investigators, journalists and NGOs need to cross reference the Land Registry with other sources, such as Companies House and the Trust Registration Service maintained by HMRC. Unfortunately, even when doing so, much information remains out of sight, making it difficult to identify the real owners of assets.

Following efforts by transparency advocates and parliamentarians, such as Baroness Hodge and Lord Agnew, the Rishi Sunak Government consulted on the transparency of land ownership in the UK. Although the results of this consultation have still not been published, the Foreign Secretary has stated that he intends to stop UK trusts from being used for illicit activities and promised an “action plan to bring full transparency around trust ownership of UK property”.

Under Keir Starmer, the new Government has vowed to shed the UK’s infamous reputation as the “London Laundromat” and re-establish the country as a global leader in the fight against corruption. Closing loopholes that allow foreign kleptocrats and criminals to funnel dirty money into prime real estate using opaque trusts, would be a good place to start. 

After all, ordinary Britons buying property must disclose their ownership on the land register. Why should money buy anonymity, especially for those with questionable wealth to hide?

To achieve the intended aim of making property ownership more transparent, the UK Government should reform our existing system to provide interoperability and allow the public to identify ownership of companies, trusts and property.

Companies House

• Companies House should not take an unduly restrictive approach in providing access to information on trusts controlling Overseas Entities.
• The UK Government should legislate to:
  • require UK companies to report the parties to trusts controlling them to Companies House
  • enable Companies House to publish information on trusts controlling UK companies and Overseas Entities

Land registries

• The UK and Scottish Governments should legislate to make it a requirement for trusts to disclose to the relevant land registry where they own land directly.
• Land registries across the UK should clearly specify the type of owners in their data: trusts, individuals, companies, overseas entities, and other types of entity.
• The UK and Scottish Governments should legislate to make it a requirement for companies and trusts to report their:
  • unique registration numbers, and
  • jurisdiction of incorporation

to the relevant land registry when acquiring ownership of land.

• Land registries across the UK should provide free bulk data on land owned by UK companies, Overseas Entities and trusts, ideally on a monthly basis.

Trust Register

• The Trust Registration Service System should capture information about trusts which directly acquired land and property before October 2020
• The public should have access to information on parties to overseas ‘Type C’ trusts that directly hold UK land and property.