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Material Discrepancy Changes

Author: Nicola Sharp  11 April 2023

Nicola Sharp of Rahman Ravelli outlines an amendment to the Money Laundering and Terrorist Financing Regulations 2022.

Changes to the reporting of material discrepancies have come into effect as part of an amendment to the Money Laundering and Terrorist Financing Regulations 2022.

Entities that carry out due diligence checks on companies under the anti-money laundering regulations are obliged to report any difference they identify between the information that they gather and the information held at Companies House. Such a difference is called a material discrepancy.

Specifically, the obliged entities must report differences in information regarding:

  • People with significant control (PSC) of a company
  • PSCs of a limited liability partnership (LLP)
  • PSCs of an eligible Scottish partnership

From 1 April 2023, however, obliged entities must only report a material discrepancy if it can be reasonably linked to:

  • money laundering
  • terrorism financing
  • the concealing of details of the customer’s business

Obliged entities must also report discrepancies throughout a business relationship, rather than just at the start.

The new regulations will also apply to the Register of Overseas Entities - meaning that obliged entities will also have to report material discrepancies about registrable beneficial owners of an overseas entity.

Nicola Sharp C 09983

Nicola Sharp


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Nicola is known for her fraud, civil recovery, arbitration and business crime expertise, her experience of leading the largest financial disputes and multinational investigations and her skills in devising preventative measures and conducting internal investigations for corporates.

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