The Clock is Ticking for overseas entities that own property and land in the UK- The Economic Crime Act 2022 and the Register of Overseas Entities (ROE)

The Economic Crime (Transparency and Enforcement) Act 2022 requires overseas entities (companies and other entities that have legal personality such as LLPs and some limited partnerships) which own real estate in the UK to register the identities of their beneficial owners and/or (in some cases) managing officers with Companies House (any individual or entity that has significant influence or control over the overseas entity). This information must be verified by a professional person practising in the UK who is subject to AML supervision, such as a notary.

Failure to verify and register overseas entities is a criminal offence incurring a fine of up to £2,500 per day or a prison sentence of up to 5 years and such entities could also face restrictions when buying, selling, transferring or leasing property in the UK. The deadline for registration of overseas entities is 31st January 2023, which may seem a distant date, but the time needed to navigate the complexities of the new registration scheme should not be underestimated. In particular, some entities will have to send notices to persons who may be beneficial owners and a month is allowed for any response to be received and verification checks carried out. Further guidance can be found at the HM Land Registry (England and Wales) and Registers of Scotland on how to update the land register with your Overseas Entity.

Scrivener Notaries have facilitated trade between London and the rest of the world for many centuries. At De Pinna we specialise in the authentication of documents and deeds issued by overseas entities and are experts in conducting due diligence on entities incorporated all over the world. We have a wide range of in-house linguists which means that we can conduct due diligence without needing translations where information is only available in languages other than English, saving time and costs for our clients.

De Pinna is the largest firm of scrivener notaries in London and we have a dedicated group of notaries who are registered as agents at Companies House and can deal with registration and verification and updating of beneficial ownership information from the simplest to the most complex of structures.

De Pinna offer a personal service and a team, headed by the notary who will act as the registration agent, who will work with you to ensure that you understand what information you need to provide to us and the most efficient way of doing so. If you would like any further information in relation to the Register of Overseas Entities (ROE), please contact:

Phillip Journeaux at phillipj@depinna.co.uk
Peter Adams at petera@depinna.co.uk
Iain Ostrowski-Rogers at iainr@depinna.co.uk