More jurisdictions now require clear disclosure of the ultimate owner or controller of real estate assets, even through layers of ownership, to curb sanctions risk and illicit finance. Rising foreign direct investment (FDI) prompts countries to impose disclosure requirements on inbound investors. Arnold & Porter’s Real Estate Beneficial Ownership (REBO) team advises developers, funds, and financial institutions on complex ownership structures to ensure compliance, transparency, asset protection, and robust financing.

Our REBO team combines advocacy, advisory, and compliance experience to meet diverse client needs. We offer guidance on public policy issues related to FDI and beneficial ownership, support inbound and outbound FDI transactions, and advise on state and federal laws. This includes counseling clients on compliance with the Agricultural Foreign Investment Disclosure Act of 1978 (AFIDA), which requires foreign persons to report certain acquisitions, transfers, and holdings of U.S. agricultural land, as well as advising on the growing body of state-level foreign ownership and disclosure laws. Our team regularly manages complex compliance projects spanning investments, financing, and strategic transactions, including registrations with state and federal agencies. 

Compliance is a core part of our practice. We represent clients before regulatory bodies, provide strategic real estate portfolio management, conduct legal compliance audits, and perform annual monitoring for real properties in jurisdictions with filing requirements. As cross-border investment expands, we provide practical, defensible strategies for companies facing AFIDA reporting obligations and state foreign ownership restrictions and disclosure requirements, helping our clients avoid regulatory pitfalls and substantial fines.