Bribery, fraud and anti-money laundering | Regulatory Outlook September 2022

Register of Overseas Entities is now live

On 1 August 2022, the Overseas Entities Register, which was introduced by the UK's Economic Crime (Transparency and Enforcement) Act 2022 went live. Overseas entities must now register and provide information about their beneficial owners or managing officers if they own or acquire UK real estate. The government has outlined sanctions for those who do not comply, including restrictions on buying, selling, transferring, leasing, or charging their land or property in the UK. For further information, please see our Insight.

HMRC updates anti-money laundering guidance for estate and letting agency

On 22 July 2022, HMRC issued updated guidance on anti-money laundering (AML) procedures for estate and letting agency businesses registered with HMRC. This guidance replaces HMRC's previous guidance that was last updated in May 2019.

Estate agency is defined very broadly for the purposes of the guidance and associated AML regulations. This can include businesses that are construction companies (in particular, developers), social housing providers and asset management companies.

All businesses that undertake estate or letting agency work should now review their AML procedures as a priority following the new guidance. For further information, please see our Insight.

Economic Crime and Corporate Transparency Bill published

On 22 September, the Economic Crime and Transparency Bill was introduced in the House of Commons. The Bill will bring in wide-ranging reforms to tackle economic crime and improve corporate transparency, and forms part of the government's continued response to the war in Ukraine.

The government stated that the Bill will deliver reforms including granting additional powers to seize and recover suspected criminal cryptoassets, as well as reforms to Companies House and to prevent the abuse of limited partnerships. Further details may be found in the factsheets for the Bill.