Checks for the companiesyou form and serve.
Check each client and the people behind it, see whose Companies House identity is verified, and watch every company each morning.
- High
- Money laundering risk for company service providers (NRA 2025)
- 30 Jun 2026
- Selling off-the-shelf companies brought into scope
- 18 Nov 2025
- Companies House identity verification became law
What the rules ask, and what we do.
From the Money Laundering Regulations 2017 and Companies House’s identity verification rules.
- 01Regs 4, 12(2), 27, 28
Check each client first
Identify and verify your client before you form a company, sell one off the shelf, or provide an address or officers. Since 30 June 2026 an off-the-shelf sale is a business relationship too.
Add each client, a person or a company, and check them in one run. A company comes with its directors and owners from Companies House. Their ID with a live selfie, by link, through Vouchsafe (on the GOV.UK register of certified services).
- 02Regs 28(4), 30A
Find who really owns it
Identify the beneficial owners behind every structure, nominees included, and report a material discrepancy with the Companies House register.
Owners traced to people from Companies House, and confirmed by your client through their details link.
- 03ECCTA 2023 · Companies House
Directors’ identity at Companies House
Since 18 November 2025 directors and people with significant control must verify their identity with Companies House; existing directors confirm it with the next confirmation statement.
Each company client shows which directors have verified and when the others are due, with a reminder two weeks ahead.
- 04Regs 33, 35 · sanctions rules
Screen for sanctions and PEPs
Enhanced checks for politically exposed persons. Tell OFSI as soon as practicable about a designated person or a breach.
UK, UN, EU and US lists and PEPs for each client and everyone behind it, and the disqualified directors register.
- 05Reg 28(11)
Keep watching
Monitor ongoing relationships, above all where you act as director, secretary, nominee or registered office, and notice when what a client asks for changes.
Each company compared with Companies House every morning: new officers or owners, a new name, address or status. Each checked client re-screened too.
- 06Regs 18, 19, 40
Your risk assessment and records
A written firm-wide risk assessment with policies that follow from it, and due diligence records kept for five years.
Every check, decision and document kept, with an audit trail and an inspection bundle. Soon A risk assessment and policies written for company services.
What we check for company service providers.
Every check in every plan. Yours are lit; pick another industry to compare.
Where the risk is.
The 2025 National Risk Assessment rates money laundering risk for trust and company service providers as high. It names these weak points.
- Complex structures and nominees
- Virtual office addresses unconnected to the owners
- Same-day online formations
- Company packages sold with a bank account
- Companies formed in bulk
- Large cash payments from overseas clients
- One-off formations with no ongoing contact
- Shell companies later used for fraud
Source: HM Treasury, National Risk Assessment 2025, paragraphs 5.220 to 5.232
Asked by company service providers.
Are we a trust or company service provider?
Yes if, as a business, you form companies or sell them off the shelf, act or arrange for someone to act as a director, secretary, partner, trustee or nominee shareholder, or provide a registered office or business address (regulation 12(2)). Selling off-the-shelf companies was added on 30 June 2026.
Do we check a client who only buys a ready-made company?
Yes. Since 30 June 2026 selling an off-the-shelf company counts as a business relationship (regulations 4 and 12(2)), so you check the client and who is behind them before the sale.
Who supervises us?
Most firms are supervised by their accountancy or legal professional body; HMRC supervises most firms whose main business is company services (NRA 2025, 5.222).
Does Stratum verify identities for Companies House?
No. That is done with Companies House itself or through an authorised agent. Stratum shows, for each company client, which directors have verified and when the others are due.
What if a client or director is on a sanctions list?
Stop, freeze anything you hold for them, and tell OFSI as soon as practicable. You see the possible match with its listing and record why it is or isn’t them.
How long do we keep the records?
Five years after the business relationship ends (regulation 40), then delete the personal data. Archived clients stay in your register for five years and are then deleted.
Start with the companies you serve.
Add them by company number: directors, owners and filing deadlines come in from Companies House, and each is watched every morning.