Looking Behind the Wall: Data Availability and Advocacy for Stronger AML-CFT Legislation in France

With its luxury apartments in fashionable Parisian arrondissements, riviera villas, chateaux, and alpine chalets, France is well known to be a preferred destination for criminals, kleptocrats and oligarchs to stash their cash in real estate. High end properties appear often in media, civil society and law enforcement investigations into illicit finance. In 2017, French authorities seized a 101-room mansion in central Paris from the vice president of Equatorial Guinea, Teodorin Obiang Nguema, after he was convicted for laundering embezzled public funds in the biens mal acquis case. Investigations by OCCRP in 2023 revealed how several politically exposed persons (PEPs) from Latin America owned properties in France, including relatives of a former transport minister of Venezuela, and the son of a former Brazilian senator implicated in the sprawling Odebrecht corruption scheme.

So it might appear surprising that France is among the top performers in the Opacity and Real Estate Ownership (OREO) Index developed by ACDC and Transparency International (TI).

Explore the Opacity in Real Estate Ownership (OREO) Index

France comes second only to England & Wales on the part of the index that assesses how well countries collect and make available that can be used to identify cases of money laundering in the real estate sector. A similar dynamic plays out in other countries, like England & Wales or South Africa, where good data frameworks mean that media and civil society are more easily able to find properties owned by PEPs, contributing to a clearer perception of the problem. Critically, however, France fares less well on the part of the index assessing the effectiveness of anti-money laundering (AML) legislation in the real estate market, ranking seventh out of 24 countries, with a score of just 6.69 out of a possible 10. This indicates that while we have better insight into the scale and nature of the problem in France than in many other countries, the legislative framework to stop dirty money entering the real estate sector has significant room for improvement.

Importantly, however, France also illustrates how good data availability allows civil society advocates to pinpoint loopholes and weaknesses in the AML framework, and push for changes that close the door to illicit cash.

In 2023, in parallel to the OCCRP investigations referenced above, ACDC, TI and TI France published the report Behind a Wall: Investigating Company and Real Estate Ownership in France. This in-depth analysis of real estate and beneficial ownership data also  highlighted cases that illustrated chinks in France’s AML armor. For example, historical ownership data was not recorded in the country’s beneficial ownership register. This meant that when Elizaveta Peskova, the daughter of Vladimir Putin’s spokesperson Dmitry Peskov, transferred her shares in a company owning French real estate to her mother shortly after being sanctioned by the US, her name no longer appeared in the register. (Since the report, French authorities have seized the apartment in Paris owned by Peskova’s mother).

Behind a Wall: Investigating Company and Real Estate Ownership in France

The study therefore helped TI France successfully advocate for improvements in national AML legislation. For example,  when French lawmakers introduced a bill aimed at freeing France from the grip of drug trafficking, TI France submitted amendments which resulted in real estate dealers and property developers — as well as persons selling and renting cars, yacht and private planes — becoming subject to AML-CFT obligations for the first time.

The bill, which was adopted by the Senate on February 4, 2025, and subsequently by the National Assembly on April 1, 2025, also strengthened the penalties for failure by obligated entities to declare their beneficial owners. Non-compliant entities now face the risk of being removed from the national business register, which is compulsory for conducting economic activity. Such penalties are crucial because the Behind the Wall report laid bare the scale of non-compliance with France’s beneficial ownership reporting requirements. More than a third (37%) of corporate owners of real estate could not be linked to the beneficial ownership register, contributing to 61% of corporate owned real estate in France being, in effect, anonymously held.

Moreover, the report has helped make the case for continued improvements in data availability. A bill adapting French law to several provisions of European Union law and transposing certain aspects of the 6th Anti-Money Laundering Directive, now widens access to the national beneficial ownership register to NGOs fighting corruption, and adds the mention of “the ownership chain, historical data, and the nationality of the various beneficial owners” to the list of information accessible to persons demonstrating a legitimate interest.

There is of course still room for improvement, particularly in terms of the usability of the register of beneficial owners and its interoperability with other property registers in France and abroad, such as registers of cars, boats, works of art, or cryptocurrency. 

Zooming out across the 24 countries assessed in the inaugural edition of the OREO Index, the data section returned a slightly lower average score than the part measuring AML legislation (5.33 out of 10, compared with 5.52). Only three countries scored above seven points in the data section, compared to seven in the AML legislation section. Among the reasons for this, international standards mandate AML-CFT obligations for designated non-financial businesses and professionals (DNFBPs). Compliance with these recommendations is regularly assessed as part of Financial Action Task Force (FATF) reviews. No such international standards or assessment mechanism exist for the collection and sharing of data on real estate transactions. FATF recommendations on beneficial ownership state only that countries “could consider” public access to the information they collect.

Moreover, on top of a poor baseline of data availability, anti-corruption NGOs in many countries likely have greater access to legal and policy expertise than they do capacity to evaluate and interrogate the available data. It is more difficult to articulate the benefits of open data without a clear picture of how it can be used to detect money laundering and contribute to legislative improvements. France provides one such example, but importantly, it also illustrates why open data and a civil society equipped to use it are a critical component in strategies to prevent money laundering through real estate.

For more information:
Charlotte Palmieri, Transparency International France
charlotte.palmieri@transparency-france.org