MEMA Guides / Counterparty due diligence
How to check a UK company before you onboard, pay or partner with it
Read the Companies House record for what it is, match the depth of your check to the relationship, and keep a decision record that a regulator, auditor or bank could follow.
- Not checkedCompanies House does not check the accuracy of the information companies fileSource
- 18 Nov 2025identity verification became a legal requirement for directors and PSCsSource
- Before you starta firm in scope must collect an excerpt of the register's beneficial ownership information before it establishes a business relationship with a company customerSource
The guide in 30 seconds
Practical guidance- 01The register is where you startIt tells you what a company has filed and when. It does not prove who you are dealing with or whether the company is sound.
- 02Match the check to the relationshipA client, a supplier, an introducer and an appointed representative candidate each trigger different rules and need different evidence.
- 03Write down the decisionA check you cannot show later did not happen. Record what you found, who decided and why.
Explore the chapters
Read them in order, or jump to the one you need.
01What a Companies House check tells you, and what it cannotThe register is a statutory record of what a company has filed. It is the right first step, and a poor last one.
02Reading the signals: status, filings, people and chargesThe Company Trust Check turns the public record into findings and a risk tier. Know what each finding means and what you should ask next.
03Match the check to the relationshipThe same company needs a different check depending on whether it is your customer, your supplier, your introducer or your appointed representative.
04Beyond the register: what else you still needThe tool says plainly what it cannot prove. These are the checks that sit alongside it.
05Worked example: a payments firm checks a new introducerAn illustrative case showing how a Review result becomes a documented decision, not a gut call.
06Put it to work: a repeatable record, and how MEMA helpsA good check is one you can repeat, explain and show to someone else. Here is a checklist, a record template and where MEMA can help.
Chapter 01 · Start here
What a Companies House check tells you, and what it cannot
The register is a statutory record of what a company has filed. It is the right first step, and a poor last one.

A Companies House check is the quickest way to learn whether a UK company exists, what state it is in and who the register says is behind it. Companies House holds the UK register of companies and makes the information available to the public. That makes it the natural first step before you onboard, pay or partner with a company.
Companies House does not check the accuracy of the information filed
That line sits on the Companies House search page. It means the register shows what a company has told Companies House. Companies House checks that filings are complete and can query or remove information, but it does not confirm that what was filed is true. A company can be active, up to date with its filings and still be run by someone who is not who they say they are.
The register is also getting stronger. Identity verification became a legal requirement for individual directors and people with significant control (PSCs) on 18 November 2025. Existing directors give their Companies House personal code with the company's next confirmation statement, new companies give it when they register, and PSCs have a 14-day window set by their situation. Until every company has filed that statement, not every director on the register will have verified. Corporate directors and officers of corporate PSCs are not yet covered. Check the current GOV.UK guidance for the rules that apply to each role.
What the register can and cannot do for you
It cannot show you
- That the person emailing you is the director named on the register
- That the bank account you were given belongs to the company
- Whether the company is sanctioned or linked to a politically exposed person
- Whether it can pay you, or is trading as it says
- Whether it holds an FCA authorisation
It can show you
- Whether the company exists and its status
- Whether accounts and confirmation statements are filed on time
- Who the officers and PSCs are on record, and when that changed
- Whether charges (security over assets) are registered
- A dated, sourced starting point for your file
Chapter 02 · What each flag means
Reading the signals: status, filings, people and charges
The Company Trust Check turns the public record into findings and a risk tier. Know what each finding means and what you should ask next.

The free Company Trust Check reads the Companies House record for a company number or name. It reports a set of findings, each with a severity of positive, info, watch, review or high, and combines them into one of four tiers: Clear, Watch, Review or High risk.
You can name the person you are dealing with. The tool then tells you whether that name appears as an active officer or PSC, appears only in historic records, or is not found. Enter the full name as it appears on the register; a nickname or a different spelling will come back as not found. It matches names only, so a match does not prove the person on the call is the person on the register.
| Signal | Severity | What it suggests | What to ask |
|---|---|---|---|
| Company is not active | High | The entity may be dissolved or in a process that ends it | Which legal entity is actually trading and who owns it now |
| Strike-off, dissolution or Gazette wording in the last 24 months of filings | High | The company may be heading for removal, or was recently threatened with it | Why, and whether the action was discontinued or is still live |
| No active officers returned | High | No one is on record as responsible | Who runs the company and why the register is not updated |
| Accounts or confirmation statement overdue | High | Weak filing discipline or a company in difficulty | For an explanation and current management information |
| Accounts due soon | Watch | Not late yet, but close | Monitor the filing date |
| Claimed person historic only, or not found | Review | The person you deal with may not hold a current role | Their actual role, authority to act and proof of identity |
| Negative net assets in the latest parsed accounts | Review | Liabilities exceed assets at the balance sheet date of those accounts | Current management accounts and a view on solvency |
| Five or more relevant changes in 24 months | Review | Frequent changes of officers, control, address, name, charges or capital | What drove the changes |
| Very recently incorporated (under 1 year) | Watch | Little or no trading history | A track record elsewhere, and how the founders are known |
| Micro-entity or dormant accounts | Watch | Valid filing, but limited public financial detail | Management accounts if scale matters; if the accounts are dormant but the company says it trades, ask why |
| Outstanding charges | Watch | Security has been given to a lender over company assets | Who holds the charge and whether it affects your claim |
From tier to action
Stage 1 of 4
Clear
No concerning finding came back. That is the register saying nothing is wrong, not a verdict that the company is safe.
- Run your normal sanctions, PEP and identity checks
- File the report with your due diligence record
Stage 2 of 4
Watch
One or more minor flags, such as a company under a year old, micro-entity or dormant accounts, an outstanding charge or accounts due within 45 days.
- Ask for the specific evidence the flag points to
- Record the answer and the reviewer's name
Stage 3 of 4
Review
A senior reviewer should look at the file, for example where the person you deal with is not a current officer.
- Escalate to your MLRO or relationship owner
- Resolve the flag before you sign or pay
Stage 4 of 4
High risk
A hard stop applies or the combined picture is poor. Do not onboard, contract or pay until the position is explained and approved.
- Record why you paused
- Decide in writing whether to decline or re-test later
Two more points matter. First, the tool reads accounts only where it can parse them, so a missing figure is not a pass: it reports revenue as found or as not publicly disclosed. Second, micro-entity accounts are valid statutory filings, but GOV.UK describes them as simpler accounts that meet statutory minimum requirements, so ask for more where size matters.
Chapter 03 · Rules differ
Match the check to the relationship
The same company needs a different check depending on whether it is your customer, your supplier, your introducer or your appointed representative.

The tool asks you to pick a relationship: client, supplier, contractor, introducer or partner. It records the choice on the report but runs the same checks for each. The choice matters for what you do next, because each relationship engages different rules. What follows describes the main ones and where they apply. Whether a rule applies to your firm depends on its permissions and activities.
The same company, four different checks
A business customer. The Money Laundering Regulations 2017 apply if you are a relevant person.
- CDD applies when you establish a business relationship (regulation 27)
- For a body corporate, obtain and verify its name, company number, and registered office address and, if different, its principal place of business (regulation 28(3)(a))
- Take reasonable measures to determine and verify the law it is subject to, its constitution, and the full names of its board and the senior persons responsible for its operations (regulation 28(3)(b))
- Identify the beneficial owner and take reasonable measures to verify them, and to understand the ownership and control structure (regulation 28(3A) and (4))
- You cannot verify a beneficial owner by relying only on the PSC register (regulation 28(9))
- Where someone acts for the customer, verify their authority and identify and verify them from a source independent of them and the customer (regulation 28(10))
- Before the relationship begins, collect an excerpt of the beneficial ownership information on the register (or confirm none is held), and do so again when you carry out CDD or ongoing monitoring later. Report any material discrepancy to Companies House (regulation 30A)
- Monitor the relationship and keep documents up to date (regulation 28(11))
A company you rely on to perform something for you.
- SYSC 8.1 sets the standard for outsourcing; whether it binds you as a rule or as guidance depends on your firm type
- Authorised payment institutions and authorised e-money institutions must tell the FCA before outsourcing any operational function, and must meet extra conditions for important ones (PSRs regulation 25, EMRs regulation 26)
- A function is critical or important if a failure would materially impair compliance, financial performance or continuity (SYSC 8.1.4R and 8.1.4AR)
- Check the provider has the ability, capacity, organisational structure and any authorisation required by law (SYSC 8.1.8R(1), where it applies to you)
- Register signals such as overdue filings, negative net assets and registered charges feed your view of financial resilience
A company that will bring you customers or act under your permission.
- Before appointing an appointed representative (other than an introducer AR), and on a continuing basis, establish on reasonable grounds that it is solvent and otherwise suitable (SUP 12.4.2R)
- Consider the fitness, propriety and financial standing of its controllers, directors and managers (SUP 12.4.4)
- Verify the information it gives you is accurate, detailed and up to date (SUP 12.4.4E)
- For an introducer AR, take reasonable care that it is suitable and, as a minimum, verify the identity of the IAR and the people responsible for it (SUP 12.4.6R, 12.4.7G)
- Make sure the FCA receives your notification at least 30 days before the AR starts regulated activities (SUP 12.7.1R), and review each AR other than an introducer AR at least every 12 months, keeping a written record (SUP 12.6A)
- Payment and e-money firms do not appoint ARs for payment services. If the introducer will do more than introduce, check whether it must be registered as your agent (PSRs regulation 34) or distributor
- If the introducer will communicate invitations or inducements to engage in investment activity, which includes credit, insurance and deposits as well as investments, or claims management activity, section 21 FSMA applies. An unauthorised person can do so only if an exemption applies or an authorised person with permission to approve promotions (section 55NA) has approved the content
- Promoting payment services is not caught, but what is said about your services must still be clear, fair and not misleading
A joint venture, referral or distribution partner.
- No single rule: treat it as the nearest of the three other relationships, based on what the partner will actually do
- Check every party to the arrangement, not just the one you meet
- Look at who controls the partner now and who has controlled it recently
- Agree in writing what each side shares, promises and pays for
Chapter 04 · Fill the gaps
Beyond the register: what else you still need
The tool says plainly what it cannot prove. These are the checks that sit alongside it.

The Company Trust Check states that it does not verify bank ownership, sanctions, politically exposed persons (PEPs), adverse media, fraud risk, live trading, affordability, creditworthiness or the identity of the person emailing you. Each of those is a separate step. Which ones you need depends on the relationship and your risk assessment.
Sanctions screening has changed this year. The UK Sanctions List became the only source of UK sanctions designations on 28 January 2026, and the OFSI Consolidated List is no longer updated. If your procedure still tells staff to search the OFSI list, update it. The separate Russia list of entities subject to financial and investment restrictions is not part of the UK Sanctions List. If you deal in securities or grant loans or credit, check it too, including entities those named companies own.
For PEPs, regulation 35 requires risk-management systems to determine whether a customer or its beneficial owner is a PEP, a family member or a known close associate. Where one is found, it requires senior management approval, adequate measures to establish source of wealth and source of funds, and enhanced ongoing monitoring.
make sure the contact details you’ve been given for the firm, match those on the Firm Checker.
That advice from the FCA is aimed at clone firms, where fraudsters copy a genuine authorised firm. It is a good habit for any counterparty claiming a permission: use the contact details on the FCA Firm Checker or Financial Services Register, not the ones in the email. The FCA notes those details are supplied by the firm, so call the number and confirm. The Warning List holds firms the FCA has published warnings about, so a firm that is not on it has not been cleared.
Chapter 05 · An invented firm
Worked example: a payments firm checks a new introducer
An illustrative case showing how a Review result becomes a documented decision, not a gut call.

All names, figures and dates in this example are invented. The report came back with eight findings and a tier of Review.
Positive: active company, one active officer, accounts appear current. Info: revenue not publicly disclosed (no accounts filed yet); three recent change filings (Samuel's resignation, Priya's appointment and the charge). Watch: incorporated five months ago, one outstanding charge. Review: Samuel Rowe appears only in historic records.
Illustrative example Not FCA figures. Use your own.
The Review finding was the one that mattered. Samuel Rowe had resigned as a director six weeks earlier. The register showed one new director, Priya Anand, and one PSC, who was neither of them. Quillmere had not told Kestrel.
What Kestrel did, and in what order
- Day 1Ran the check and saved the reportTier Review, decision label Manual review recommended.
- Day 2Escalated to the MLROThe MLRO asked Quillmere who now controls the company and why Samuel Rowe was not a director.
- Day 4Received an explanationSamuel had stepped back to a consultancy role. Quillmere supplied a signed authority and the lender's charge agreement.
- Day 6Ran separate checksSanctions and PEP screening on Priya, Samuel and the PSC; Financial Services Register and Warning List searches, and a written confirmation from Quillmere that it carries on no regulated activity; adverse media; photo ID checked against Priya on a video call.
- Day 8Decision recordedApproved on limited terms with a six-month re-check.
Kestrel approved Quillmere with conditions. Quillmere could introduce customers but could not describe or market Kestrel's services without Kestrel's prior sign-off. Kestrel re-ran the check at six months and again whenever Quillmere gave notice of a change in control.
Chapter 06 · Make it routine
Put it to work: a repeatable record, and how MEMA helps
A good check is one you can repeat, explain and show to someone else. Here is a checklist, a record template and where MEMA can help.

In our experience, weak counterparty files usually fail on process, not on the check itself. The check was done, but no one can show what was found, who looked or what was decided. Fix that with a short written procedure that every relationship type follows.
A repeatable counterparty check
Classify the relationship
Client, supplier, contractor, introducer, AR candidate or partner. This sets the rules and the depth of the check.
Run the register check
Use the Company Trust Check or Companies House directly. Enter the person you are dealing with and save the report.
Triage the tier
Clear and Watch go to the relationship owner. Review and High risk go to the MLRO or a senior reviewer.
Run the checks the register cannot do
Sanctions, PEPs, FCA Register, adverse media, payment details and the identity of the person.
Decide and record
Approve, approve with conditions, or decline. Record who decided, on what evidence and when.
Re-check on a schedule and on triggers
Set a review cycle by risk. Re-check on a change of control, a new director or an overdue filing.
What your decision record should hold
- Company name, number and the date and time of the check
- The saved report and the person named on it
- The relationship type and why that depth of check applies
- Findings you queried, the answers and the evidence received
- Sanctions, PEP, FCA Register and adverse media results where relevant
- Who approved, any conditions, and the date of the next review
Is your counterparty process ready?
Tick each item you can evidence. Your ticks stay in this browser only.
MEMA is led by former FCA regulators. Our financial crime, compliance outsourcing and appointed representative and principal firm services cover this work, and you can run the free Company Trust Check on the MEMA website today. Book a free scoping call and we will tell you where your current process is thin.
| Question | Short answer |
|---|---|
| Is a Clear result enough to onboard? | No. It means the register raised no concern. You still need sanctions, PEP, identity and other checks that fit the relationship. |
| Does the tool verify the person I am dealing with? | No. It checks whether a name appears on the register. Identity verification is a separate step. |
| Do I need to do this for suppliers as well as clients? | Different rules apply. The customer-only regulation 30A duty does not cover suppliers, but outsourcing standards and good practice still call for diligence. |
| How often should I re-check? | Set it by risk and re-check on triggers such as a change of control, a new director or overdue filings. |
| Can I save the result? | Yes. After you enter your work email, the report can be printed or saved as a PDF. |
Where this comes from
Sources
Every number and rule in this guide comes from these pages. Check them before you rely on anything, as rules change.
- Companies House: Find and update company information (search page)
- GOV.UK: About Companies House
- GOV.UK: When you need to verify your identity for Companies House
- GOV.UK: People with significant control (PSCs)
- GOV.UK: Micro-entities, small and dormant companies
- Money Laundering Regulations 2017, regulation 27 (application of CDD measures)
- Money Laundering Regulations 2017, regulation 28 (customer due diligence measures)
- Money Laundering Regulations 2017, regulation 30A (reporting discrepancies in registers)
- Money Laundering Regulations 2017, regulation 35 (politically exposed persons)
- FCA Handbook, SYSC 8.1: Outsourcing
- FCA: Payment Services and Electronic Money, Our Approach (paragraph 3.39 and 4.58 to 4.61)
- FCA Handbook, SUP 12: Appointed representatives
- FCA: Responsibilities and how to oversee your appointed representatives
- Financial Services and Markets Act 2000, section 21
- FCA: How to check a firm or individual is authorised
- FCA: Financial Services Register
- GOV.UK: The UK Sanctions List
- GOV.UK: Moving to a single list for UK sanctions designations (28 January 2026)
- Payment Services Regulations 2017, regulation 34 (agents)
- GOV.UK: UK financial sanctions general guidance
- GOV.UK: Russia: list of persons named in relation to financial and investment restrictions
- Pay.UK: Confirmation of Payee
This guide is general information, not legal or regulatory advice. Rules and FCA expectations change; check the sources and take advice on your firm's circumstances.
