Start with the right legal entity.
Capture the company’s legal name, registration number and jurisdiction. Use the registered identity to distinguish similarly named businesses and keep the checks attached to the correct customer.
A registered office, a trading address and an individual’s home address serve different purposes. Label them clearly rather than treating one as a substitute for another.
Connect identity, authority and ownership.
The person signing up might be a director, an employee or another authorised representative. Their document check establishes information about that person; the case also needs evidence of the relationship and authority relevant to the engagement.
Beneficial ownership concerns the individuals who ultimately own or control the customer. A director, representative and beneficial owner may be the same person, but those roles should not be assumed to be interchangeable.
HMRC: required customer due diligence measuresUse the register as part of the evidence.
Companies House information can help establish company details. It must not be the only evidence used to fulfil the beneficial ownership obligations identified in Regulation 28(9). Layered ownership or conflicting information needs further examination.
HMRC: documentary evidenceKeep Companies House verification separate.
AML customer due diligence and Companies House identity verification are distinct processes. AMLCode does not provide Companies House identity verification or issue Companies House personal codes.
Companies House: verification through an ACSPDo we need to verify every director in the same way?
Do not use the directors list as an automatic one-size-fits-all checklist. Identify the people relevant to the customer, representation and beneficial ownership, then apply the measures required for the case.