Register of Overseas Entities Verification – How it works

Register of Overseas Entities Verification – How it works

On 1 August, the register of overseas entities went live. The Register is kept by Companies House and contains details of overseas entities which own UK property and who owns and controls them, with the aim of increasing transparency and fighting economic crime. To find out more, read our register of overseas entity guide.

The challenges of verifying information

Although the new rules are based on existing practices around Anti-Money Laundering (AML) and the persons of signification control (PSC) regime there are some key distinctions. One of these is the need to verify the information before it appears on the register of overseas entities. Given one of the major criticisms of the PSC register is the lack of verification, the new approach should have been welcomed. However, law firms and other professional advisors have instead reacted with nervousness due to possible criminal sanctions for getting it wrong. The Law Society advised its members to demonstrate “extreme caution” when it comes to verifying information.

Verification can be carried out by what Companies House refers to as UK Regulated Agents, also referred to as relevant persons in the legislation. These can be: credit institutions and financial institutions; auditors, insolvency practitioners, external accountants and tax advisers; independent legal professionals; trust or company service providers; or estate agents and letting agents.

Elemental CoSec is a company service provider and authorized UK regulated agent with extensive experience of dealing with AML, the PSC register, Companies House and overseas entities. Here we our experts explain our approach to the verification stage.

How to verify information for the Register of Overseas Entities

Once the overseas entity has identified its beneficial owners, served them a s12 notice and obtained the relevant information, the information must be verified. The overseas entity may or may not have had external help to identity their ownership structure; however, they must seek independent help from a UK regulated agent to verify all the relevant information.

The approach to verifying will vary depending on whether the relevant jurisdiction has a public registry or not. Table 1 provides a summary of our approach in each case.

Where there is no public registry and a corporate service provider is used, the corporate service provider needs to append evidence. A lawyer would not.

Table 1 – Verification of the Overseas Entity


Evidence of VerificationPublic registryNo public registry
Name of Overseas EntityPublic registry

Evidence from:
• lawyer in jurisdiction
• Or corporate service provider
Country of incorporation or formationIf Registered office – As above,
If Elemental - None
If Otherwise - lease or similar.
Registered or principal office
Service Address
E-mail AddressUnique code sent to email and entered through our portal
Legal form of the entity and the law by which it is governed
Public registryEvidence from:
• lawyer in jurisdiction
• Or corporate service provider
Any public register in which it is entered and, if applicable, its registration number in that register

Table 2 shows our approach to how we would verify an individual beneficial owner (the evidence for a corporate would be slightly different).

Table 2 – Verification of an individual beneficial Owner


InformationEvidence of Verification
Name, date of birth and nationalityPassport and e-verification (with liveness check)
Residential AddressCertified bank statement or utility bill
Service AddressIf Residential address – As above
If Elemental or Registered Office – None
If Otherwise – Lease or Similar
Date on which the individual became a registrable beneficial ownerStatement from a lawyer in the jurisdiction
Statement from a professional with evidence
Extract from a company beneficial ownership registry
Ownership conditions
SanctionsCheck UK Sanctions List

Unlike AML rules, there is no risk-based approach so those undertaking verifications are advised to follow a more rigorous checklist-based approach to ensure everything is covered off.

Registration of Overseas Entities Verification – A Practical Example

Elemental CoSec was invited to present to representatives from some of the UK’s leading law firms. Here is an extract of the webinar where our directors, Nick Lindsay and Tobias Latham provide a practical example of verification.




How we can help with verification and more

Our register of overseas entities verification service is part of a fully managed service that includes: helping to identify the beneficial owners, verification, and registering the information with Companies House. For more information, contact us.



We’re here to keep things simple

If you would like to find out more about our services and how we can help support your business, please get in touch.

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