Dirty Money and Trust Issues: Tackling the Final Frontier in Secret Property Ownership
For years, the UK’s property market has carried an uncomfortable nickname: the “London Laundromat.” Luxury homes in Belgravia, penthouses in Mayfair, and quiet country estates have all doubled as safe deposit boxes for dirty cash. Successive governments have promised to close loopholes and shine a light on hidden wealth. Progress has been made, but one frontier of secrecy still stands tall: trusts.
New research from Transparency International UK reveals that while reforms have exposed many offshore companies holding UK real estate, trusts continue to shield vast amounts of property from scrutiny. Our findings show that over 236,500 properties worth at least £64 billion in England and Wales are owned via trust structures—many linked to individuals facing corruption charges, sanctions, or allegations of suspicious wealth.
From Crusades to Contemporary Laundering
Trusts are not a modern invention. Born in medieval times, they allowed crusading knights to hand stewardship of their estates to trusted managers while they marched east. At their core, trusts separate ownership from benefit:
- Settlor – the person transferring property into the trust
- Trustee – the legal holder of the asset
- Beneficiary – the ultimate recipient of wealth
Unlike companies, trusts lack legal personality. That makes them harder to trace. A property might appear in a land register under a trustee’s name, but the true beneficiary could remain hidden behind layers of legal paperwork.
For many households, trusts can be legitimate estate-planning tools. But for oligarchs, kleptocrats, and tax evaders, they provide an all-too-convenient cloak of invisibility.
A Billion-Pound Blind Spot
Our analysis uncovered 170 properties worth £2.5 billion acquired through suspicious trust arrangements since 2010. Of these, 138 properties—worth £2.1 billion—were bought in just the last 15 years.
Examples include:
- A £61 million London apartment linked to the partner of oligarch Alexander Ponomarenko, once associated with the notorious “Putin’s Palace.” Despite links to sanctions, no freezing order has been issued in the UK.
- An £8.3 million mansion tied to sanctioned Russian politician Igor Komarov, again not frozen by UK authorities.
- £130 million of property connected to Azerbaijan’s ruling Aliyev family, first exposed by the Organized Crime and Corruption Reporting Project.
- £40 million in commercial property linked to a jailed Singaporean money launderer.
- £55 million of assets once held by Malaysia’s former Finance Minister through trusts, never fully tested in court after his death.
These cases barely scratch the surface. They illustrate how trusts have become the go-to vehicle for concealing wealth in plain sight.
Loopholes in the Reform Era
Since Russia’s invasion of Ukraine in 2022, the UK has taken significant steps to clean up property ownership. Offshore companies must now disclose their beneficial owners under the Register of Overseas Entities (ROE). At the same time, the People with Significant Control (PSC) Register sheds light on domestic company ownership.
Yet trusts remain the Achilles’ heel. They can disguise ownership in at least three ways:
- Offshore companies controlled by trusts
- UK companies controlled by trusts
- Direct trust ownership of land
Offshore Companies
Nearly 5,500 overseas entities—one in six listed on the ROE—declare a trust in their ownership chain. Combined, they control 23,000 properties worth £17.5 billion. While these companies must report trust information to Companies House, the regulator has no power to publish it.
Upcoming regulations (due August 2025) will allow applications for trust data, but the hurdles are high. Applicants must already know the trust’s name—a near impossibility for investigators. Legitimate interest must also be proven case by case, unlike the EU where journalists and NGOs are presumed to qualify under AMLD6.
UK Companies
Oddly, UK companies controlled by trusts are even more opaque than offshore ones. They only need to disclose the trustee, not the settlor or beneficiary. Our research found 49,000 properties worth £9 billion held in this way.
Direct Trust Ownership
The murkiest area is land owned outright by trusts. HMRC’s Trust Registration Service should be the answer, but it only applies to trusts formed after 2020 and requires applicants to demonstrate an investigation is already underway. Information is slow, incomplete, and often useless.
We estimate at least 164,500 properties are owned directly by trusts in England and Wales. Add in those owned by corporate trustees, and the figure exceeds 236,500.
The Bakiyev Case Study
One example highlights the shifting landscape. Maxim Bakiyev, son of Kyrgyzstan’s former president, was accused of embezzlement and laundering public money. Investigations linked him to a £3.5 million mansion in Surrey purchased via a Belizean company.
When the ROE rules took effect in 2022, the house was transferred into a UK-administered trust. Subsequent checks revealed Bakiyev himself as the beneficiary. His case illustrates how wealth once hidden in offshore companies is migrating into trusts as new transparency rules take hold.
Why It Matters
The stakes are high. If left unchecked, trusts could undermine years of progress in fighting money laundering. Transparency is not about targeting ordinary families using legitimate estate structures. It is about preventing criminals and kleptocrats from exploiting legal grey zones to dodge sanctions, avoid tax, and distort housing markets.
Ordinary buyers must disclose ownership at the Land Registry. Why should those with the dirtiest money enjoy greater anonymity?
Fixing the System
Transparency International UK proposes a clear set of reforms:
Companies House
- Publish trust information linked to overseas and UK companies.
- Require full disclosure of all trust parties, not just trustees.
Land Registries
- Mandate disclosure of trust ownership where land is held directly.
- Standardise data to show whether an owner is an individual, company, overseas entity or trust.
- Require companies and trusts to provide unique registration numbers and jurisdictions of incorporation.
- Offer free bulk datasets on company and trust-owned land.
Trust Register
- Expand the Trust Registration Service to include trusts created before 2020.
- Allow public access to overseas trusts directly holding UK property.
A Political Test
Both the previous Conservative Government and the new Labour Government have acknowledged the urgency of tackling illicit finance. Former ministers promised an “action plan for full transparency around trust ownership”, while Prime Minister Keir Starmer has pledged to strip away the UK’s reputation as a haven for dirty money.
Delivering on these promises will require confronting powerful interests and updating outdated legal frameworks. The choice is stark: continue to provide cover for oligarchs and money launderers, or bring Britain’s property market out of the shadows.
Conclusion
The UK has made progress since 2016, but loopholes remain wide enough for billions in suspect wealth to slip through. Trusts, once medieval tools for managing estates, have become the last bastion of secrecy in British property ownership.
Shining a light on this hidden world is not just a matter of fairness to ordinary homeowners—it is a matter of national security, global reputation, and the integrity of Britain’s housing market.
As Transparency International’s research shows, reform is possible and urgently needed. The final frontier of secrecy can and must be tackled, ensuring that no one—no matter how wealthy or well-connected—can hide behind a trust.
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