UK Money Laundering Regulations: reporting material beneficial ownership discrepancies—scope, CDD and ongoing monitoring, materiality examples, and reporting to Companies House or HMRC (companies, trusts and overseas entities)

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Practice notes

Practice Note

This Practice Note sets out guidance on the obligation to report material discrepancies in beneficial ownership information.

It is aimed at organisations within scope of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692, as amended, when engaging with clients or customers that are corporate bodies and trusts, including overseas entities.

It is not a guide for corporate bodies or trusts on their own obligations concerning beneficial ownership information and registration.

The Money Laundering and Terrorist Financing (Amendment) (No 2) Regulations 2022, SI 2022/860, in force from 1 April 2023, expanded the scope of discrepancy reporting so that it applies:

throughout the life of the business relationship, rather than being confined to client inception only
to entities recorded on the Register of Overseas Entities (a public register of the beneficial owners of overseas entities which own land and property in the UK)

Before establishing a business relationship with:

a company
an unregistered company
a Limited Liability Partnership (LLP)
an eligible Scottish partnership
a trust which is subject to registration under the MLR 2017, or
an overseas entity which is subject to...

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Web page updated on 22/05/2026

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