Anti-money laundering

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Anti-money laundering

Important changes in relation to the Register of Overseas Entities

28 Jan 2026
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What you need to know about verifying beneficial owners, and reporting discrepancies.

The Register of Overseas Entities (ROE) came into force on 1 August 2022 through the new Economic Crime (Transparency and Enforcement) Act 2022.

Overseas entities that want to buy, sell or transfer property or land in the UK must register with Companies House. Additionally, verification checks on their registrable beneficial owners or managing officers must be carried out a UK-regulated agent before they can be added to the ROE.

What has changed?

Firms cannot use the ROE as a sole source of information to verify beneficial ownership. This expectation already exists when it comes to verifying Person/s with Significant Control (PSC) on Companies House.

Firms should use multiple sources of information when verifying beneficial owners.

The ROE has been added to the discrepancy reporting regime. If information you obtain from the ROE conflicts with what your client has provided, you must report it to Companies House.

You must only report a material discrepancy if it can reasonably be linked to one or more of the following:

  • money laundering
  • terrorist financing
  • concealing details of the business of the customer.

Examples of ‘material discrepancy’ include:

A difference in name, a missing entry for a PSC or a registrable beneficial owner; an incorrect entry for: nature of control, date of birth, correspondence address, for the date the individual became a registrable person.

Companies House are reminding that a discrepancy report should not be used in place of a SAR and vice versa. In some cases, both – a SAR and a discrepancy report will have to be submitted.

For more information, please refer to Companies House’s guidance.

What does it mean for you?

Update your firm’s AML policy and Client Due Diligence (CDD) procedures without delay. If you have staff members, ensure they are aware of these changes and follow the updated processes.

Further guidance

Further guidance and support on risk management and other components of Money Laundering Regulations compliance is available on our AML webpage. You can also contact us on +44 (0)20 7367 1347 or via email at [email protected].

Future of supervision

On 21 October 2025, the Government confirmed that the AML supervision for accountancy, legal and Trust and Company Service Provider sectors will move to a single professional services supervisor (SPSS), specifically the Financial Conduct Authority.

While this is a big shift, implementation is likely to take years. In the meantime, AAT will continue as the AML supervisor for our licensed members and carry out our normal responsibilities, including Practice Assurance Reviews and risk assessment activities. Therefore, our members must ensure full compliance with the MLR 2017. Find more on the consultation response here.

AAT Comment offers news and opinion on the world of business and finance from the Association of Accounting Technicians.

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