IntroductionBeneficial ownershipAnonymous real estate in the United Kingdom and the United States of AmericaUnited KingdomUnited States of AmericaOrthodox strategy: RegistrationTransparency initiatives: The United Kingdom, the United States of America, the European UnionUnited KingdomUnited States of AmericaThe European UnionReflectionsAppendix A: The concept of “ownership” in world legal systemsOrigins of “ownership” and “beneficial ownership” in trust lawOwnership in civil law: Usufruct, fiducie and TreuhandOwnership in IslamAppendix B: Beneficial Ownership Transparency1. The 2014 G20 High-Level Principles on Beneficial Ownership Transparency2. Financial Action Task Force (FATF) (a) FATF 40 Recommendations (2012, amended February 2023) and (b) Guidance on Transparency and Beneficial Ownership (October 2014), Best Practices on Beneficial Ownership for Legal Persons (October 2019) and Guidance on Beneficial Ownership of Legal Persons (March 2023)