Bribery, fraud and anti-money laundering | UK Regulatory Outlook February 2023

Companies House preparing to enforce Register of Overseas Entities

The Register of Overseas Entities, which was introduced by the Economic Crime (Transparency and Enforcement) Act 2022, went live on 1 August 2022. 

Overseas companies owning UK real estate are now required to register and provide information about their beneficial owners or managing officers. The transitional period for registering affected overseas entities ended on 31 January 2023. 

Failure to comply and update the register is a criminal offence, which may result in fines, potential criminal sanctions for officers and an inability to complete major dealings with UK properties. 

On 1 February 2023, Companies House announced that it is currently assessing and preparing cases for enforcement action. Further regulations are to follow that will empower it to impose financial penalties on land owned by non-compliant organisations.

Update on Economic Crime and Corporate Transparency Bill

The Economic Crime and Corporate Transparency Bill 2022 is currently progressing through Parliament. 

Having completed all its stages in the House of Commons, the bill has now passed onto the House of Lords, with a second reading held on 8 February 2023. The bill's amendments currently include the introduction of a "failure to prevent" fraud, false accounting or money laundering offence. 

The bill will also introduce strengthened information requirements for companies, including identity identification requirements for all new and existing registered company directors, people with significant control and those delivering documents to the registrar. 

The House of Lords has published a research briefing on the bill.