Company clients: directors, beneficial owners and the PSC register

The company itself

Under regulation 28(3) you must obtain and verify the company's name, company number, registered office and, if different, its principal place of business. You must also take reasonable measures to find out and verify the law it is subject to, its constitution, and the full names of the board of directors and the senior persons responsible for its operations.

Directors

The CCAB guidance (Appendix B) says the names of directors should be verified on a risk based approach, and that some directors will also need their identity verified.

Beneficial owners

Under regulation 28(4) you must identify the beneficial owners, take reasonable measures to verify their identity, and understand the ownership and control structure.

You do not satisfy your obligation to take reasonable steps to verify the identity of beneficial owners by relying only on information contained in a PSC register.

The Regulations make an exception for companies listed on a regulated market.

Reporting discrepancies

Regulation 30A requires you to report material discrepancies between what you find and the information on the register. Companies House guidance explains that, since 1 April 2023, a discrepancy only needs reporting if it can reasonably be linked to money laundering, terrorist financing or concealing details of the business.

Companies House identity verification is different

Directors and people with significant control now verify their identity with Companies House. That is a Companies House requirement. It does not replace your own customer due diligence on a client.