The Invisible Owners

The Invisible Owners, produced by CEFILAT in partnership with the Financial Transparency Coalition (FTC), examines the beneficial ownership registries of seventeen countries in Latin America and the Caribbean and measures, using a unified methodology, the distance between what the law provides and what the registries actually do. The universe comprises the sixteen countries of mainland Latin America except Venezuela, plus Belize. Eleven of them currently have an operational beneficial ownership registry: Argentina, Belize, Brazil, Colombia, Costa Rica, Ecuador, Nicaragua, Panama, Paraguay, Peru and Uruguay. Of the remaining six, two have bills under consideration, one combines identification obligations without a centralized registry with a pending reform initiative, and three have neither.

The study builds two indices on the same three dimensions (accessibility and governance, quality and scope, and enforcement and deterrence) and on the same 0 to 12 point scale. The de jure index measures what laws and implementing regulations establish; the de facto index measures what registries do in practice. The difference between them is read as an implementation gap and can be broken down by dimension. The evidence combines primary legislation, open data, mutual evaluations by the Financial Action Task Force (FATF) and eight semi-structured interviews with experts from Argentina, Belize, Brazil, Colombia, Panama, Paraguay and Peru, covering legislation in force up to March 2026. The de facto index also covers Costa Rica, Ecuador and Uruguay.

The first finding is regulatory homogeneity. Eight of the eleven countries with a registry score 6 or 7 points on the de jure index, and the full range runs from 6 to 9. All of these frameworks were designed to satisfy FATF Recommendation 24 and the peer reviews of the Global Forum on Transparency and Exchange of Information for Tax Purposes, and they resemble one another more closely than the comparative literature suggests. The second finding is that none of the eleven registries is accessible beyond the State: there are no public registries in the region, no partially public ones, and no access route for third parties with a demonstrated legitimate interest. This is a matter of legislative design rather than administrative capacity, and it can only be corrected through legal reform.

The third finding is the size of the gap. Across the ten countries measured on both indices, the average de jure score is 7.1 points and the average de facto score is 4.3, a gap of 2.8 points out of 12. Of that total, 1.9 points correspond to enforcement and deterrence and 1.1 to quality and scope. Penalty regimes are the best designed of the three dimensions, with an average de jure score of 3.3 out of 4, and they are almost never applied: in Argentina, Colombia, Peru, Belize and Paraguay there are no documented penalties for failing to declare beneficial owners.

There is also an information problem: in most countries it is impossible to calculate what share of obliged entities has actually filed a declaration, because the universe of obliged entities is not published. Paraguay is the exception: its open data make it possible to establish a compliance rate of 68.1% out of 46,482 registered entities. In Panama, the coverage of close to 85% reported by the regulator is calculated on an unpublished denominator, in a context of corporate clean-up affecting more than 360,000 legal persons that have been dissolved or suspended.

The country cases illustrate different aspects of the gap. In Argentina, penalty amounts remained unchanged for twenty-two years, until Law 27,799 of January 2026 multiplied them by a thousand and introduced annual indexation; the regime's coverage stood at around 60% for fiscal year 2021. Brazil adopted the most comprehensive penalty regime in the region in 2025, but its effective application is deferred to 2027 and 2028 depending on company size. Ecuador scores highest on both indices thanks to a three-percentage-point surcharge on corporate income tax that is applied through the tax return itself, without depending on the authorities' enforcement capacity.

In all eleven countries with a registry, custody lies with agencies whose primary mission is not transparency: the tax administration in five cases, and central banks, company registries, superintendencies or economy ministries in the rest. In every case, the custodian agency's pre-existing confidentiality regime prevails over the law that created the registry. The report proposes separating three functions that are currently merged, without creating new agencies: custody of the information, which can remain where it is; access, guaranteed by a legal provision that prevails over that confidentiality regime, with direct access for financial intelligence units, public prosecutors and oversight bodies, and a route for third parties with a legitimate interest; and oversight and disclosure, entrusted to a body with a specific transparency mandate.

The report also identifies three low-cost measures that can precede any broader reform: publishing the universe of obliged entities so that coverage can be verified; establishing mandatory channels for authorities that detect false or outdated information to report it to the registry; and indexing penalties wherever that clause is missing. Finally, it notes that beneficial ownership registries reveal who controls a company, but not what it owns or where, an issue that will be addressed in a dedicated publication on asset registries.