On 1 August 2022, Companies House launched the UK register of overseas entities (ROE), which is a key provision of the Economic Crime (Transparency & Enforcement) Act 2022 (Act).
The Act requires overseas entities that own or acquire property in the UK to register with Companies House and provide information regarding their beneficial owners.
The provision applies to:
Upon registration, entities will receive a unique ID, which can be provided to the Land Registry when purchases, sells, transfers, leases or charges of UK real estate occur.
It’s important to note that the Act prohibits overseas entities from carrying out the above mentioned operations unless they have an ID, it is therefore important for entities to request it timely.
Following the registration, the name of the overseas entity and its beneficial owners will be publicly available.
The information inputted in the system must also be verified by a UK-based agent that is supervised under the Money Laundering Regulations 2017, such as a legal professional, a trustee or a company service provider.Failure to comply will result in a daily fine of up to £2,500, potentially subjecting the entities’ officers to imprisonment.
Trustees will have to assess whether structures holding UK real estate fall within the scope of the Act, and if so, they will have to timely provide the required information to Companies House.