New IMF AML Guidance pushes for beneficial ownership transparency and tackles risks from major financial centres

On 25 June 2026, the IMF published its Guidance Note for Addressing Anti-Money Laundering/Combating the Financing of Terrorism Issues in Surveillance, Financial Sector Assessment Programs, and Use of Fund Resources. This Guide can help address one of the main problems of the anti-money laundering system. One of the central reasons the system fails to curb illicit financial flows is that, in addition to weak international standards, countries tend to approach anti-money laundering and transparency requirements as a check-the-box exercise. What prevails is an attitude of doing the bare minimum simply to prevent being blacklisted or poorly rated. Instead, this Guide helps show the main decision-makers in ministries of finance that anti-money laundering measures are not just a matter for the financial intelligence unit. As the Guide rightly notes, money laundering can have “macroeconomic impact” and financial crimes can “undermine financial stability, economic growth, and quality of institutions.” This should be enough to convince government economists of the need to prevent financial crime. If that is not enough, the Guide also reminds Treasuries around the world that the IMF will be watching this issue very closely.

The Guide also demonstrates the IMF’s engagement on many of the transparency policies that the Tax Justice Network holds dear.

First, the Guide makes it clear that the IMF can go beyond current international standards (e.g. those of the Financial Action Task Force (FATF)) and propose more appropriate (and ambitious) measures when needed: “where appropriate, the Fund may recommend a closer alignment of Fund member countries’ policies with best practices that go beyond the FATF standards or mutual evaluation recommendations.”

A great example of where the IMF has gone further than the FATF is in promoting public beneficial ownership transparency, one of the main policy priorities reflected in the Tax Justice Network’s Financial Secrecy Index and our Roadmap to Effective Beneficial Ownership Transparency. The Guide describes how the IMF required some countries receiving Covid-19 funding to publish information on beneficial owners: “One such measure was to ‘publish’ the names of the beneficial owners of legal entities awarded procurement contracts—a novel measure in an area that is at high risk of corruption. While not prescribed in the FATF standards, the publication of such information in member countries has contributed to enhancing transparency of public procurement, strengthening fiscal governance, and detecting fraudulent deals through increased public oversight and financial management information systems.”

Second, the Guide highlights the need to increase transparency in the real estate sector, aligning with our recent reports on Beneficial Ownership of Real Estate Around the World. The Guide notes: “given the wide range of impacts of illicit financial flows, including as a contributing factor for real estate bubbles in some countries, the Fund has promoted beneficial ownership transparency in a wide range of sectors with a focus on real estate.”

Third, the Guide recognises many of the financial crime risks present in countries with offshore centres targeting non-residents. These risks are the focus of many of the Financial Secrecy Index indicators, such as:

• “misuse of opaque legal persons and arrangements” – assessed by Indicators 2, 3, 4 and 7 of the Financial Secrecy Index. We have also written several papers on the abuse of trusts.
• “economic citizenship/residency schemes” – assessed by Indicator 13 of the Financial Secrecy Index. We have also written about this here.
• “strict banking secrecy” – assessed by Indicator 1 of the Financial Secrecy Index.

Fourth, consistent with the findings of the Financial Secrecy Index ranking (e.g. the top 10 countries), the Guide makes it clear that illicit financial flows are mainly enabled by major countries rather than by small secrecy jurisdictions (although they all share some responsibility): “While SDS [small developing states] with offshore characteristics facilitate only a minor share of global cross-border financial services as compared to the advanced economies with global financial centres, they face significant challenges in mitigating ML/TF risks from non-resident activity disproportionate to the size of the domestic economy and institutions.” (emphasis added).

The Guide rightly points out the spillover effects of each country’s frameworks: “Cross-border proceeds of financial crimes (or IFF) and weak AML/CFT frameworks generate cross-border spillovers”, particularly when it comes to major and small offshore centres that function as conduit or destination jurisdictions: “weak policies to address ML [money laundering] and economic crime in the transit and destination countries create arbitrage opportunities for illicit actors in search of financial institutions and company formation for misuse, as well as attractive jurisdictions in which to integrate criminal proceeds.”

In complete alignment with the Financial Secrecy Index ranking, the Guide recognises the major responsibility of advanced economies towards other countries:

“Advanced economies are also frequently destination jurisdictions for laundered funds originating in less-advanced economies, reflecting criminals’ preference for stable environments offering a wide range of financial products and services. Where such assets are not effectively detected, confiscated, and recovered, the resulting safe-haven effect can exacerbate instability in source countries by entrenching illicit economies, weakening state capacity, and undermining development—underscoring the fight against ML/TF as a global public good.”

Despite acknowledging the responsibility of major financial centres, the Guide fails to highlight the urgency of requiring advanced economies to be the first to strengthen their legal frameworks and enforcement. On the positive side, when proposing targeted policies for different types of countries, the Guide closely aligns with the Tax Justice Network’s policy recommendations for major financial centres: deepening understanding of cross-border risks and the risks associated with the misuse of legal entities and arrangements; enhancing beneficial ownership transparency across sectors, including the real estate sector; leveraging anti-money laundering measures to tackle tax crimes; and enhancing international cooperation on risk assessment and mitigation (e.g. supervision, investigation, prosecution and asset recovery).

In this context, we hope the IMF will take this Guide even further by recommending concrete policy measures in advanced economies to neutralise the cross-border spillover effects of secrecy and money laundering risks, such as:

• Developing beneficial ownership transparency for assets, particularly through the registration of all relevant assets (e.g. real estate), and ensuring that information is centralised, digitised, available online and integrated with other registries (e.g. the beneficial ownership registry) to help identify the beneficial owners of legal vehicles and assets in conduit and destination countries and recover assets involved in financial crimes;
• Increasing international cooperation through the exchange of information (e.g. encouraging advanced economies to share information with lower-income countries on a non-reciprocal basis or to publish relevant statistics) and engaging in more comprehensive mutual assistance. This would support investigations and prosecutions both in advanced economies and in the countries from which illicit funds originate.

Finally, we hope the IMF will adopt and promote the use of the Financial Secrecy Index by countries’ financial intelligence units and obliged entities to identify and address geographic risks. (For instance, the EU Anti-Money Laundering Regulation’s “high-risk factors” related to customer due diligence include many of the elements assessed by the Financial Secrecy Index, such as exchange of information, banking secrecy and beneficial ownership (Annex III, 3.f)). When assessing or assisting a country, the IMF could consider the Secrecy Score of that country’s main economic partners as a way of identifying high-risk flows. In other words, the Index could be used to identify secrecy risks among a country’s principal economic partners when assessing foreign direct investment, portfolio investment, trade or bank deposits. The Financial Secrecy Index could also be used for geographic risk assessment at the micro level, based on specific transactions processed through financial institutions, particularly in countries where the financial sector lacks robust risk models and other measures to prevent illicit financial flows.

In conclusion, just as the IMF did in relation to opaque bank ownership, this Guide continues to demonstrate leadership by calling for more ambitious reforms. It provides an important opportunity for key decision-makers in ministries of finance to take ownership of—and recognise the self-serving benefits of—transparency reforms. At a time when a UN Tax Convention is being negotiated to establish stronger international rules to combat illicit financial flows, this Guide helps advance the discussion on policies that go beyond existing international standards.