September 28 ¦ International Day for Universal Access to Information

Transparency as a defence against financial crime

September 28, the International Day for Universal Access to Information, highlights a principle with direct relevance to financial crime prevention: effective accountability depends on access to reliable information. For anti-money laundering professionals, investigators, regulators, journalists and civil society, information is not simply a public-policy concern. It is often the starting point for identifying the movement, concealment and enjoyment of illicit wealth.

Money laundering rarely begins with a suspicious bank transfer. It begins with a predicate offence that generates proceeds: corruption, fraud, tax crime, drug trafficking, human trafficking, environmental crime, cybercrime, sanctions evasion or another profit-driven offence. Those proceeds may then be moved through companies, accounts, trusts, property, trade arrangements, virtual assets or intermediaries. Limited access to relevant information makes each stage harder to detect and investigate.

Information access and the financial crime lifecycle

The value of information access differs across the stages of a financial crime case. Before an offence is identified, public records, procurement data, court decisions, company filings and land register information can reveal inconsistencies that merit scrutiny. They may expose a public official connected to a supplier, repeated awards to newly formed entities, unusual asset ownership patterns or corporate structures with no evident commercial purpose.

After suspicion arises, investigators need timely access to accurate information on legal entities, financial transactions, assets, tax records and cross-border connections. Delays can be decisive. Funds can be transferred through multiple jurisdictions, converted into high-value goods or virtual assets, or dissipated through cash withdrawals and nominee arrangements before an investigative order is obtained.

At the asset recovery stage, information determines whether authorities can trace, freeze, confiscate and return criminal proceeds. A conviction for a predicate offence may have limited practical impact if the assets have been hidden behind opaque ownership arrangements or transferred to third parties in other countries.

Access must therefore be understood as more than publication. Information must be available in a form that is timely, searchable, structured, accurate and usable across borders. Thousands of scanned records that cannot be searched or compared offer far less value than interoperable data that can be examined efficiently.

Bastian Schwind-Wagner _Follow

"Access to reliable information is a practical requirement for preventing and investigating financial crime. It helps authorities, regulated firms and civil society identify the predicate offences that generate illicit proceeds, trace assets and expose attempts to conceal ownership or control.

Beneficial ownership information is one important element of this framework, alongside transparent procurement, property, corporate and enforcement data. Its value depends on accuracy, verification, timely access and safeguards that protect legitimate privacy and due-process rights."

Beneficial ownership registers matter, but verification matters more

Beneficial ownership registers are an important part of the transparency framework. They can help establish who ultimately owns or controls a company, partnership or other legal arrangement. This is essential because legal ownership may differ from actual control.

Criminals and corrupt actors may use nominees, layered entities, bearer-style instruments where still permitted, informal control rights or offshore structures to distance themselves from assets. A register that captures only the name of a nominal shareholder will not reliably identify the person who benefits from, directs or controls the entity.

Yet a beneficial ownership register is not a complete answer to financial opacity. Its effectiveness depends on the quality of the underlying data, the scope of entities covered, the frequency of updates, meaningful sanctions for false reporting, and mechanisms to verify submitted information. Registers also need clear links with other sources, including company registries, tax authorities, licensing bodies, procurement systems and property records.

Where access is available only to competent authorities, the information must still be rapid, dependable and capable of being shared lawfully with foreign counterparts. Where some level of public access is provided, policymakers must balance transparency interests with privacy, personal security and data-protection rights. The appropriate balance will differ by jurisdiction, but inaccurate or inaccessible ownership data serves neither privacy nor crime prevention.

Public information can expose predicate offences

The connection between transparency and money laundering is often described through beneficial ownership, but the predicate offence deserves equal attention. Laundering is the process used to disguise criminal proceeds. Preventing it also requires better visibility of the crimes that produce those proceeds.

Public procurement is a clear example. Open and well-structured procurement information can help identify bid rigging, conflicts of interest, inflated pricing, repeated use of the same intermediaries and contracts awarded to entities linked to politically exposed persons (PEPs). When contract data can be compared with corporate ownership, political disclosures and enforcement records, corruption risks become more visible.

Land and property information can play a similar role. Real estate remains attractive for laundering proceeds because it can absorb substantial value, may be acquired through corporate vehicles, and can provide both investment returns and a credible explanation for wealth. Information on property ownership, purchase prices, mortgages, transfers and associated legal entities can assist in identifying suspicious patterns.

Access to court records, sanctions lists, regulatory decisions and official gazettes also supports financial institutions’ risk assessments. These sources cannot replace customer due diligence (CDD), transaction monitoring or direct verification. They can, however, help regulated firms identify adverse information, assess source-of-wealth claims and understand the risks connected to clients, counterparties and jurisdictions.

Transparency does not mean unrestricted disclosure

Financial crime controls require information sharing, but they also require safeguards. Suspicious transaction reports (STRs), intelligence assessments, witness information and active investigative records cannot generally be made public without harming investigations, exposing reporting entities or creating risks for individuals.

A strong information access framework distinguishes between data that should be public, data that should be available to authorised users, and data that must remain confidential. It should also include clear legal bases for access, audit trails, retention limits, security controls, correction procedures and remedies for misuse.

This distinction is particularly important for financial institutions. Banks, payment firms, virtual asset service providers (VASPs), accountants, lawyers and trust and company service providers (TCSPs) may hold information that is highly relevant to an investigation. Their obligations to report suspicious activity must operate alongside professional secrecy, confidentiality rules, data protection requirements and due-process safeguards. These frameworks should not be treated as mutually exclusive. Properly designed rules can protect legitimate rights while enabling lawful detection and reporting of suspected crime.

Data quality is a financial crime control

Poor data quality can create an illusion of transparency. A registry may contain names, addresses and company numbers, but still be ineffective if entries are incomplete, outdated, duplicated or unverified. Variations in spelling, transliteration, date formats and entity identifiers can prevent meaningful matching across records. The result is missed connections, false alerts and unnecessary investigative workload.

Authorities should prioritise unique identifiers, consistent reporting standards and mechanisms for correcting errors. Reporting entities should have proportionate ways to flag discrepancies identified during customer due diligence (CDD). Such discrepancy reporting is useful only if registrars and competent authorities can assess, resolve and record the outcome.

For cross-border investigations, interoperability is especially important. Criminal networks do not organise themselves according to domestic database boundaries. A fraud scheme may involve victims in one country, mule accounts in another, shell companies in a third and assets held elsewhere. Information systems that cannot communicate across agencies or borders leave investigators working with fragments of the same case.

A practical commitment on September 28

The International Day for Universal Access to Information is an opportunity to examine whether transparency measures work in practice. The key question is not merely whether information exists. It is whether the right people can lawfully obtain accurate information in time to prevent, detect, investigate and recover the proceeds of crime.

For the financial crime community, this means supporting stronger access to verified corporate and beneficial ownership information, better procurement and asset transparency, effective inter-agency cooperation, and secure channels for international information exchange. It also means recognising that information access must be paired with investigative capacity, data protection, judicial oversight and meaningful enforcement.

Money laundering thrives where proceeds can be hidden, ownership can be obscured and public decisions cannot be examined. Access to information cannot eliminate predicate offences or stop every laundering scheme. It can, however, make criminal structures more difficult to construct, easier to identify and less able to retain the benefits of crime.