Verifying beneficial owners

For a company client you must identify each beneficial owner and take reasonable steps to verify who they are (MLR 2017 reg 28(4)). Certivus now keeps a record of the evidence behind every verification, so you can show a supervisor what you relied on.

Record a verification

Open the company, open People, go to Owners and people with control and press Record verification on the owner. Choose Verified or Exempt.

You can no longer pick "Verified" or "Exempt" from the owner's edit form. Owners marked that way before this change keep their status; the card says "Verified before evidence was recorded" so you can add the evidence.

Only a firm owner, a manager or your firm's MLRO can record a verification or an exemption.

Verified

Say how you got the evidence:

• Their completed identity check. Use this when the owner is linked to a client file, or was sent their own identity check, and it has finished. The document, the date and the evidence tier come from the check.
• Original document seen or Certified copy seen. Choose the document, enter its date and upload a copy.
• Register record. For a company that owns your client, for example its Companies House record.

Exempt

Give the reason the owner does not need verifying, in at least 20 characters. The reason is kept on the owner and in the client's history.

Evidence tiers

Guidance for the accountancy sector (AMLGAS 2026 B.1.5) ranks evidence by who issued it:

1. Government, a court, or a digital verification service on the GOV.UK DVS register.
2. Other public sector bodies or local authorities.
3. Regulated financial services firms, such as banks.
4. Other firms regulated under the Money Laundering Regulations.
5. Anyone else.

A passport, a photocard driving licence, a national identity card or a Northern Ireland Electoral Identity Card is always tier 1.

If your evidence is below tier 1, say why it is reliable and independent of the person (B.1.6). Certivus will not record the verification without that reason.

Electronic identity checks and the DVS register

An electronic check only counts as tier 1 if the service was on the GOV.UK DVS register when the check was done. If it was not, Certivus records the check as tier 5 and fills in the reason for you. You can add paper documents as well, which the guidance recommends.

Owners that are companies

A company that owns your client is not the end of the chain. Certivus saves a corporate PSC from Companies House as a corporate owner, and the owner card and the client's to-do list ask you to identify the people behind it.

1. Find out who owns or controls the company.
2. Add each person who owns more than 25%, or controls it, as an owner of your client.
3. Record the company owner's verification from its register record and name the people behind it.

Someone acting for the company

The person who deals with you on the company's behalf must also be identified and verified (MLR 2017 reg 28(10)). The client's to-do list shows Verify the person acting for the company until at least one director, or other officer or authorised person on the people list, has had an identity check or a paper document check.

If nobody has, approving the company shows a warning. The MLRO can still approve by ticking Approve as an MLRO override and saying in the reason how they satisfied themselves who is acting for the company.

In the compliance pack

The compliance pack lists each owner with its evidence tier, the document, the date, how it was obtained, whether an electronic check was on the DVS register, and the reason for any evidence below tier 1.

Companies House officers and PSCs

The People tab shows officers and people with significant control from the newest saved Companies House record. If no copy exists, choose Fetch from Companies House. An empty saved list is different from a record that could not be loaded; failures show a message so you can try again.

A PSC already on your owners list is marked Recorded as a beneficial owner. For another current PSC, choose Add as beneficial owner, then verify them in Owners and people with control. Adding someone does not verify them.

Person acting for the company shows officers and authorised people recorded on the owners list and their verification status. Choose the contact person in Details. The ownership comparison and group structure are also in People.

When sending an owner their first check creates an individual client record, their recorded nationality and country of residence are carried over. A full date of birth is copied when known; a register birth month and year never become an invented full date.