On February 20, 2025, Transparency International Latvia (Delna) organized an online seminar titled “What Do We Know About the Beneficial Owners of High-Value Assets in Latvia?”. During the event, we presented compiled data on Latvia’s asset registers, including their availability, data volume, interoperability, and filtered or unfiltered access for law enforcement agencies and various public groups. The seminar featured representatives from the Financial Intelligence Unit (FIU) and the Enterprise Register (ER), who provided a broader insight into the implementation of Regulation 2024/1624 in Latvia and the need for new asset registers in the country.
The Chief State Notary of the Enterprise Register, Laima Letiņa, explained that the implementation of the Regulation in Latvia enhances corporate transparency by disclosing beneficial owners. This helps prevent the illicit use of companies, such as money laundering, and allows entrepreneurs to assess the reliability of potential partners. She emphasized that a beneficial owner is not only a profit recipient but also someone who controls the company. The new regulation mandates that foreign legal entities acquiring high-value assets in Latvia must register their beneficial owners. Otherwise, they will be denied the ability to secure property rights until the required information is provided. Letiņa mentioned that the first registrations have already taken place, including one for a Swiss company.
During the event, we identified several shortcomings in data registers and their availability:
- Latvian Aircraft Register does not collect complete historical ownership records, making it difficult to track the sales and purchase chains of certain assets. We concluded that a unified approach to historical data registration is needed at the European level. If asset registers do not require full ownership details, it can create a loophole that can be used as a safe haven for sanction evasion.
- Although the new AML legislative package does not explicitly require the creation of an art register, FIU representative Kārlis Pūce highlighted significant challenges regarding the transparency of art transactions. He noted that while many valuable artworks are publicly identifiable, the lack of a unified register makes it difficult to track transactions and monitor changes in ownership. Pūce emphasized that this regulatory gap allows the art market to be exploited for money laundering purposes. The European Union currently does not have legal provisions mandating the collection of information on artworks, except for the Copyright Directive, which governs the sale of artworks but does not include ownership tracking requirements. However, anti-money laundering (AML) regulations have applied to art market intermediaries since the adoption of the Fifth Anti-Money Laundering Directive (AMLD5). These requirements state that art galleries and auction houses are subject to AML regulations if the value of a single transaction or linked transactions reaches €10,000 or more.
- Although a specific transposition deadline has not yet announced, we identified irregularities with Directive (EU) 2024/1640 regarding FIU access to information in the Aircraft Register. While Article 21 of the Directive requires that the FIU be granted at least direct and immediate access to administrative information, FIU representatives can currently only obtain this data upon request and in a filtered manner. In contrast, unfiltered access has been granted to the FIU in the Ship Register, while in the Land Register, access is provided based on inter-agency agreements, allowing for direct but filtered access—even though it should be unfiltered, as required by Article 21(1)(b)(iii) of the Directive. Other registers comply only with minimum access standards.
- Authentication in Latvian asset registers, such as the Land Register, is currently only available to certain EU member states, which may hinder financial supervision cooperation.5. Decision-makers have not yet reached an agreement on the procedure for creating and maintaining expanded beneficial ownership information.
To gain broader feedback on the situation in Latvia, from February 25 to 28, TI Latvia’s project manager Jēkabs Kārlis Rasnačs participated in a workshop on political priorities and advocacy. in Berlin, Germany. During the workshop, we discussed the results of the comparative study on the availability of asset registers in the project’s participating countries, identified the strengths and weaknesses of each country, and analyzed their compliance with the minimum standards set by the 2024 EU AML Regulations and Directives.
We concluded that in the coming year, it will be essential to pay close attention to the Constitutional Court proceedings (Case No. 2024-01-01) regarding the publication of information about joint-stock company shareholders in the Business Register. The proceedings are currently suspended as the Constitutional Court has referred the matter to the Court of Justice of the European Union. The outcome of the case will be significant at the European Union level and for the ongoing fight for data transparency.
Funded by the European Union’s Internal Security Fund. Views and opinions expressed are however those of the author only and do not necessarily reflect those of the European Union. European Union can’t be held responsible for them.
