Around the globe, corrupt actors exploit anonymity to hide stolen wealth and amass even more ill-gotten gains. Obscuring their true identities across borders and through mazes of anonymous companies and trusts, they hoard assets and rob the public of critical resources.
According to a recent report, corruption is one of the main risks linked to the misuse of companies across the Middle East and North Africa (MENA) region, alongside tax crimes and financial fraud. In many cases, this corruption is driven by high-level government officials. These broader concerns have also come into focus amid allegations in the case of Riad Salameh, the former governor of Lebanon’s central bank. Investigations by Lebanon, the European Union and the United States have alleged that Salameh – who was first appointed in 1993 – embezzled US$300 million from the central bank between 2002 and 2015 in collaboration with his brother, who acted as his advisor. Although the allegations have not been proven, he has since faced scrutiny for his role in Lebanon’s economic collapse.
But the systems that allow this are beginning to change, as more and more countries – including in the MENA region – strengthen regulations for beneficial ownership transparency. These reforms aim to bring these shadowy figures, and the opaque structures that enable them, into the light.
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To better understand how these reforms are taking shape in practice, Transparency International assessed eight countries in the region that have begun implementing beneficial ownership transparency. We found that valuable progress has been made in recent years, but more specific steps are needed to stop the flow of dirty money and deliver real benefits for the people of the region.
What is beneficial ownership transparency?
Beneficial ownership transparency ensures that the real people who ultimately own, control, or benefit from a company, trust, or asset can be identified. This prevents the corrupt from hiding behind relatives, shell companies or complex corporate structures.
The Financial Action Task Force (FATF) sets global anti-money laundering standards on beneficial ownership transparency. Non-compliance can lead to “grey listing”, which carries economic and reputational consequences. For example, Algeria and Libya were grey listed in 2024, due in part to weak beneficial ownership regulations.
Our assessment of eight countries in the MENA region is organised around ten thematic pillars needed for an effective beneficial transparency framework, including: a clear definition of beneficial owners, regular risk assessments, verified and accessible ownership information for companies and trusts, anti-money laundering obligations, domestic and international cooperation and bans on common tools like bearer shares and nominees.
How strong is beneficial ownership transparency in the Middle East and North Africa?
Transparency International reviewed eight countries in the region – Algeria, Egypt, Jordan, Lebanon, Libya, Morocco, Palestine and Tunisia – and found that, overall, progress is underway. Each has taken the crucial first step of comprehensively defining who qualifies as a beneficial owner. However, ensuring that this information is accurate, up to date and easily accessible to those working to trace dirty money remains a work in progress.
Few countries have conducted sufficient and regular risk assessments to understand how corrupt actors are exploiting the system. Almost none require sufficient information from legal arrangements like trusts – a significant loophole. Few coordinate the verification of data and only a couple allow public access for watchdogs that can help ensure accuracy and identify gaps. Within countries, many still maintain barriers that block information-sharing among authorities, hindering investigations, and only two support international coordination.
Most crucially, Algeria, Jordan, Morocco and Tunisia have all begun to establish centralised registers – one of the most essential steps. In our assessment, most countries performed at least to an average standard, with Algeria, Morocco and Palestine demonstrating particularly strong frameworks.
Based on our findings, three priority areas stand out as the most critical for governments to focus on next.
Beneficial ownership transparency frameworks across eight MENA countries
Assessing risk
National Risk Assessments (NRA’s) are essential for countries seeking to establish robust beneficial ownership transparency. Conducting comprehensive evaluations allows countries to understand how the corrupt could use existing systems – and loopholes – within the country so they know where to focus. When regularly reviewed every three years, it also allows the tracking of progress over time, so countries can see if their measures have been effective. Sharing the results with relevant authorities and gatekeeper professions like banks and lawyers ensures they too see the gaps and can work to fix them. More broadly, publishing the results also holds countries accountable and ensures anyone working in the field has access.
This is a major area in need of improvement among the countries assessed. Jordan, Lebanon, Palestine and Morocco have conducted comprehensive assessments in the past three years. Algeria conducted its first-ever assessment last year, but it remained general rather than examining specific money laundering risks for individual entities. Other countries, such as Egypt and Tunisia, conducted assessments in the past but have not updated them recently. Of all the countries assessed, only Algeria published the full results, and while there’s some indications that Jordan, Palestine and Lebanon shared them with key professions in the financial sector, this could not be definitively confirmed.
Ensuring access to high-quality data
One of the main purposes of collecting beneficial ownership information is to enable authorities and other stakeholders to trace dirty money and identify the individuals behind it. If those responsible for this work cannot access the data – or if the information is outdated or inaccurate – that purpose is defeated.
A digital, centralised beneficial ownership register is the most effective way to ensure this. In 2022, the FATF updated the global anti-money laundering standard on beneficial ownership transparency, requiring all countries to create registers. Companies and other legal entities must be required to provide this information and keep it up to date. And all relevant authorities – from within the country and internationally – must be guaranteed access.
Ideally, registers should be available publicly, allowing journalists, civil society and academia to join in the effort of verifying information and investigating wrongdoing. As was recently established in the EU, these kinds of professions have legitimate interest and should be granted specific access alongside authorities..
Among the countries assessed, such access varies significantly. Algeria,Morocco and Tunisia are the only countries that clearly define which authorities may access their registers, ensuring they can obtain information whenever needed – and the three countries have established centralised registers, meaning all data is collected in one place. Algeria goes further by granting public access and setting a rapid response timeframe for authorities. In others the situation is less clear: Egypt, Libya, and Jordan allow “competent authorities” access but do not define which these are, which could threaten their ability to get information quickly. Lebanon’s decentralised system means information is retained in provincial commercial registers, complicating access.
In terms of the quality of information, Algeria and Morocco once again lead the pack on paper. They require register authorities themselves to verify data, while Jordan only requires checks on suspicious cases and several others have no specific verification mandates. Almost all of the countries require prompt updating of registers upon changes, but without verification these provisions have limited efficacy in practice.
Access to information about legal arrangements like trusts is more limited. Few countries recognise them at all, but because they are privately arranged and can come from outside the region, they still exist in these jurisdictions and can be a loophole for the corrupt. Only Morocco and Tunisia have specifically incorporated such arrangements into their registers. However, every country except Algeria allows authorities to request information from banks and financial institutions. This ultimately provides some access but may still lead to delays or inaccurate information.
Facilitating cooperation
The corrupt purposefully spread their holdings across different types of assets, in different countries around the world to avoid detection – making it all the more essential for authorities to be able to work together both domestically and internationally.
Among the countries assessed, domestic cooperation shows mixed progress. Algeria, Libya and Palestine all allow the free sharing of information among national authorities, while others impose legal or procedural barriers. In terms of mechanisms for data exchange, most still rely on case-by-case requests for access to beneficial ownership information rather than direct access to the registers, which can delay cooperation.
Cross-border cooperation faces even greater barriers. Algeria and Jordan impose no legal restrictions, but it is more difficult among the rest. Some like Morocco and Egypt require alignment with national laws, specific agreements or judicial approval, which can severely hinder timely access and in some cases prevent it entirely. Ultimately, all countries should move toward centralised beneficial ownership registers that are readily accessible to relevant authorities both domestically and internationally.
Transparency Now
The Transparency Now: Strengthening Anti-corruption Efforts in the EU Southern Neighbourhood project is funded by the European Commission and implemented jointly by the United Nations Interregional Crime and Justice Research Institute and Transparency International, Transparency International EU, alongside national chapters in Jordan, Lebanon, Morocco, Palestine and Tunisia.
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The project aims to deliver targeted support for policy reform, technical advice, and peer-to-peer collaboration to strengthen anti-corruption mechanisms and encourage reporting in the EU Southern Neighbourhood.
What is the way forward?
Each of the eight countries assessed have shown their commitment to beneficial ownership transparency in recent years. Now, they must refine their regulations to ensure its purpose is actually fulfilled.
Transparency International specifically recommends:
- Institutionalise regular risk assessments: As detailed above, countries can only understand what’s going on – and what’s needed – if they conduct regular comprehensive assessments and share them with authorities, key professions and the public.
- Build centralised, digital registers of beneficial ownership: Half the countries reviewed are at least on their way, but every one should develop its register to ensure timely and accurate information, not just for authorities but for all those with a stake in tracking dirty money.
- Mandate verification by register authorities: Old or false information isn’t just ineffective, it can actually threaten accountability by throwing investigators off the right track. It’s essential that register authorities themselves cross-check data to keep it accurate.
- Require the registration of both domestic and foreign trusts operating within their borders: Even though trusts don’t exist in the same way as in other countries, they still offer an opportunity for obscuring wealth unless their beneficial owners are listed in registers.
- Remove obstacles hindering access to and use of beneficial ownership information: For beneficial ownership information to matter, authorities have to be able to access and use data efficiently.
The adoption – and effective implementation – of beneficial ownership regulations is urgently needed not only in these eight countries, but across the entire MENA region. With one of the lowest average regional Corruption Perceptions Index scores, public sector corruption continues to endanger lives and livelihoods across the region. Schemes enabled by opaque ownership structures only deepens these crises – particularly when those in power are among those looting public resources.
Against this backdrop, the efforts made so far offer promise, but sustained progress is needed to close remaining gaps and ensure that no one can hide behind anonymous companies, trusts or similar vehicles.