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
  1. 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.
  2. 02Match the check to the relationshipA client, a supplier, an introducer and an appointed representative candidate each trigger different rules and need different evidence.
  3. 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.

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.

2 min read · 1 sections

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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
Companies House: Find and update company information (search page)

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.

Not checked
accuracy of what companies file
18 Nov 2025
identity verification became mandatory for directors and PSCs
Over 25%
of shares or voting rights is one of the tests for a PSC
The others are the right to appoint or remove most directors, and significant influence or control.

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
Up next · Chapter 2Reading the signals: status, filings, people and charges

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.

3 min read · 2 sections

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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.

The main findings, what they mean and what to ask
SignalSeverityWhat it suggestsWhat to ask
Company is not activeHighThe entity may be dissolved or in a process that ends itWhich legal entity is actually trading and who owns it now
Strike-off, dissolution or Gazette wording in the last 24 months of filingsHighThe company may be heading for removal, or was recently threatened with itWhy, and whether the action was discontinued or is still live
No active officers returnedHighNo one is on record as responsibleWho runs the company and why the register is not updated
Accounts or confirmation statement overdueHighWeak filing discipline or a company in difficultyFor an explanation and current management information
Accounts due soonWatchNot late yet, but closeMonitor the filing date
Claimed person historic only, or not foundReviewThe person you deal with may not hold a current roleTheir actual role, authority to act and proof of identity
Negative net assets in the latest parsed accountsReviewLiabilities exceed assets at the balance sheet date of those accountsCurrent management accounts and a view on solvency
Five or more relevant changes in 24 monthsReviewFrequent changes of officers, control, address, name, charges or capitalWhat drove the changes
Very recently incorporated (under 1 year)WatchLittle or no trading historyA track record elsewhere, and how the founders are known
Micro-entity or dormant accountsWatchValid filing, but limited public financial detailManagement accounts if scale matters; if the accounts are dormant but the company says it trades, ask why
Outstanding chargesWatchSecurity has been given to a lender over company assetsWho 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

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.

Up next · Chapter 3Match the check to the relationship

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.

4 min read · 2 sections

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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))

Where to look first

  • Client

    Money Laundering Regulations 2017, regulations 27, 28, 30A and 35.

  • Supplier

    SYSC 8.1, or the PSRs and EMRs outsourcing provisions for payment and e-money firms.

  • Introducer or AR

    SUP 12 and the FCA's principal oversight page; section 21 FSMA for financial promotions; PSRs regulation 34 for payment agents.

  • Partner

    Whichever of the above matches what the partner will actually do.

Up next · Chapter 4Beyond the register: what else you still need

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.

2 min read · 1 sections

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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.

Seven checks to run next to the register

  • Sanctions

    Screen the company, its officers and its owners against the UK Sanctions List, and consider whether a designated person owns or controls it, even if the company itself is not listed.

  • PEPs

    Where the MLRs apply, decide whether the customer or its beneficial owner is a PEP, family member or known close associate.

  • Adverse media

    Search for news or enforcement action naming the company and its people. Set out in your policy what you search and what you keep.

  • FCA Register

    If the counterparty claims to be authorised or registered, check the FCA Firm Checker or Financial Services Register for its status and permissions.

  • Payment details

    Confirm the account belongs to the company before first payment, using name checking and a bank-issued document.

  • The person

    Verify the individual you are dealing with, and their authority to act, separately from the company.

  • Financial standing

    Ask for management accounts or other evidence where size, solvency or dependency matter.

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.
FCA: How to check a firm or individual is authorised

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.

Up next · Chapter 5Worked example: a payments firm checks a new introducer

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.

2 min read · 3 sections

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All names, figures and dates in this example are invented. The report came back with eight findings and a tier of Review.

Quillmere: findings by severity (illustrative)
Positive3 findings
Info2 findings
Watch2 findings
Review1 findings
High0 findings

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

  1. Day 1
    Ran the check and saved the report
    Tier Review, decision label Manual review recommended.
  2. Day 2
    Escalated to the MLRO
    The MLRO asked Quillmere who now controls the company and why Samuel Rowe was not a director.
  3. Day 4
    Received an explanation
    Samuel had stepped back to a consultancy role. Quillmere supplied a signed authority and the lender's charge agreement.
  4. Day 6
    Ran separate checks
    Sanctions 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.
  5. Day 8
    Decision recorded
    Approved 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.

Up next · Chapter 6Put it to work: a repeatable record, and how MEMA helps

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.

3 min read · 4 sections

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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

  1. Classify the relationship

    Client, supplier, contractor, introducer, AR candidate or partner. This sets the rules and the depth of the check.

  2. Run the register check

    Use the Company Trust Check or Companies House directly. Enter the person you are dealing with and save the report.

  3. Triage the tier

    Clear and Watch go to the relationship owner. Review and High risk go to the MLRO or a senior reviewer.

  4. Run the checks the register cannot do

    Sanctions, PEPs, FCA Register, adverse media, payment details and the identity of the person.

  5. Decide and record

    Approve, approve with conditions, or decline. Record who decided, on what evidence and when.

  6. 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.

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Where MEMA can help

  • Onboarding and KYB procedures

    We design client onboarding and know-your-business procedures that fit your risk assessment.

  • Third-party due diligence

    We review how you assess suppliers and outsourcing arrangements, and what the file would show a regulator.

  • Risk-based escalation

    We set tiers, owners and decision records so a Review result always has an answer.

  • AR principal due diligence

    We support principals assessing and monitoring appointed representatives and introducers.

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.

Questions people ask
QuestionShort 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.
You have reached the endSee the sources

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.

  1. Companies House: Find and update company information (search page)
  2. GOV.UK: About Companies House
  3. GOV.UK: When you need to verify your identity for Companies House
  4. GOV.UK: People with significant control (PSCs)
  5. GOV.UK: Micro-entities, small and dormant companies
  6. Money Laundering Regulations 2017, regulation 27 (application of CDD measures)
  7. Money Laundering Regulations 2017, regulation 28 (customer due diligence measures)
  8. Money Laundering Regulations 2017, regulation 30A (reporting discrepancies in registers)
  9. Money Laundering Regulations 2017, regulation 35 (politically exposed persons)
  10. FCA Handbook, SYSC 8.1: Outsourcing
  11. FCA: Payment Services and Electronic Money, Our Approach (paragraph 3.39 and 4.58 to 4.61)
  12. FCA Handbook, SUP 12: Appointed representatives
  13. FCA: Responsibilities and how to oversee your appointed representatives
  14. Financial Services and Markets Act 2000, section 21
  15. FCA: How to check a firm or individual is authorised
  16. FCA: Financial Services Register
  17. GOV.UK: The UK Sanctions List
  18. GOV.UK: Moving to a single list for UK sanctions designations (28 January 2026)
  19. Payment Services Regulations 2017, regulation 34 (agents)
  20. GOV.UK: UK financial sanctions general guidance
  21. GOV.UK: Russia: list of persons named in relation to financial and investment restrictions
  22. 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.

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