A small but significant pair of amendments have been introduced to strengthen the UK’s anti-money laundering framework. These changes were implemented via Schedule 2 of the ECCTA 2023 (Consequential, Incidental and Miscellaneous Provisions) Regulations 2025 and are now live here.
What’s Changed?
Regulation 28
Clarification has been added to confirm that the Register of Overseas Entities must not be solely relied upon when verifying beneficial ownership. This aligns its treatment with the Companies House register, reinforcing the need for robust, independent checks.
Regulation 30A
The Register of Overseas Entities is now formally included in the discrepancy reporting regime, ensuring that inconsistencies identified during due diligence are flagged appropriately.
Why Does This Matter?
These updates close potential gaps in the verification process and strengthen transparency obligations for firms subject to the MLRs. Compliance teams should review their procedures to ensure they reflect these changes immediately.
What Should Firms Do Now?
- Update internal policies and procedures to reflect the amended Regulations, particularly around beneficial ownership verification.
- Review reliance practices: Ensure that checks on beneficial ownership do not depend solely on the Register of Overseas Entities.
- Enhance discrepancy reporting processes: Incorporate the Register of Overseas Entities into your existing discrepancy reporting framework.
- Train staff: Communicate these changes to compliance teams and relevant stakeholders to ensure awareness and proper implementation.
- Monitor further guidance: Stay alert for any updates from supervisory bodies or HM Treasury that may provide additional clarification.