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20220310 The UK’s Economic Crime (Transparency and Enforcement) Bill 2022

Hello and welcome to The Financial Crime Risk and Compliance BLOG/cast with me, Nigel Morris-Cotterill.

This episode is published the 10th March 2022

You can listen at

20220310 The UK’s Economic Crime (Transparency and Enforcement) Bill 2022

Hello and welcome to The Financial Crime Risk and Compliance BLOG/cast with me, Nigel Morris-Cotterill.

This episode is published the 10th March 2022

It is available in text on my blog at


In this episode: The UK’s Home Secretary has published the long awaited Economic Crime (Transparency and Enforcement) Bill 2022. What’s in it, what isn’t and should be and what is and shouldn’t be?

We will be looking at Part 1 of the Bill which deals with the registration of companies and information relating to their ownership and assets.

The Bill is almost a cross-bench Bill. Almost but not quite. It is a very fast moving Bill: it was introduced on 1 March 2022. It has already had dozens of amendments, many of which have been agreed outside the House, a new version of the Bill being presented to Parliament on 7th March when its sponsor, Home Secretary Priti Patel, led a debate on the Bill and encouraged both Committee and the House of Lords to, basically, pass it on the nod.

That’s what happened with the USA PATRIOT Act. Should Britain’s legislation be pushed through in a similar fashion or should it be properly considered, even if some urgent measures are introduced by Regulation or even short amendment to existing law?




You might find it helpful to open a copy of the Bill to refer to it as you listen, as well as, perhaps, open a copy of the script for this BLOG/cast. Links are further down the page.

Everything about this Bill is open to question, not the least its title. I’ve been in this field for decades and one of the earliest questions was ″what’s the difference between financial crime and economic crime″ and the answer was never satisfactory. Indeed, the term ″economic crime″ largely fell out of use.

To demonstrate: Europol says ″Economic crime, also known as financial crime, refers to illegal acts committed by an individual or a group of individuals to obtain a financial or professional advantage. ″

The OECD puts ″Economic and Financial Crime″ on the same page where it says ″Economic and financial crime, faced by donors and developing countries alike is a major obstacle to development. Resources that could support a country’s development are lost through criminal acts like corruption, tax evasion, money laundering, and others. The “spoiler” effects on countries’ development processes are diverse, and particularly severe for fragile states: economic crime, including illicit financial flows, diverts much needed resources needed to rebuild countries’ public services, from security and justice to basic social services such as health and education.″ So it uses both terms and does not differentiate between them.

There is a basic rule in drafting: if two things are the same, call them the same; if they are different, call them something different.

One of the answers that was given all that time ago, is that economic crime has a systemic effect on a country’s finances – in short, it might destabilise economies. As we have learned over the past 25 years or so, money laundering and bribery/corruption are capable of destabilising economies – and so is paying people to influence elections.
Realistically, the distinction between financial crime and economic crime seems to have been eroded.

But there is one feature that I think does actually make a difference: it is still possible to commit an offence that can destabilise economies but which is not done for the purpose of making, or not directly making, money.

Those, I think, can properly be classified as economic crimes – even though the same conduct might also fall under money laundering and, therefore, be a financial crime.

I suspect that the real reason that this Bill has this name is that those working on it have their heads filled with sanctions, which are termed ″economic sanctions″ and that they simply didn’t stand back and think clearly.

But I could be wrong so, we’ll need to decide later whether the title of the Bill is correct or whether it should have been called ″The Financial Crime Bill 2022.″

The primary driver for the Bill coming before Parliament at this point in time is the invasion of, and atrocities in, The Ukraine. I am not going to discuss that here: it’s a separate topic. Also, I am not going to discuss, in any detail, the question of sanctions.

Let’s just take it as read that, around the world to an inconsistent degree economic sanctions are being imposed against

a) Russia’s leaders
b) Russia’s central bank and financial system
c) trade with Russia
d) financial transactions with Russia
e) assets of the above overseas, directly or indirectly held
f) assets of those with business or personal connections with any of the above.

A big part of this Bill is because the UK has been stung by the absolutely justified criticism of its registration scheme for companies and, in particular, foreign companies owning significant assets in the UK. Note that this is not the same as foreign owned companies that are registered in the UK.

The important thing to understand is that Companies House is not a regulator: it has no regulatory function save insofar as it issues penalties against and/or strikes off companies that do not comply with reporting requirements. Insofar as the details of owners, directors, etc. is concerned, it is purely a registrar and has no remit beyond that.

There are civil penalties for the late filing of Returns (as annual statements of various matters including accounts are termed) these ramp up really quickly, starting at 150 pounds for being less than a month late to 1,500 for being more than six months late. Actually, failing to file accounts on time is a criminal offence although, in the absence of an aggravating factor, such as the company having been a vehicle for fraud, it is unlikely that any prosecution would take place, at least in the past. The civil penalty and the prospect of being struck off is generally considered sufficient.

In 2016, it became a requirement for persons with significant control of limited companies and Limited Liability Partnerships but not public companies , to be identified in the company’s register. They are known as ″Persons with significant control″ and, because governments refuse to operate without acronyms is known as the ″PSC Register.″

This is not a toothless requirement: ″Failure to provide accurate information on the PSC register and failure to comply with notices requiring someone to provide information are criminal offences, and may result in a fine and or a prison sentence of up to two years.″

The UK has declared that it intends to meet an OECD standard on the declaration of the true owners of a company known as the ultimate beneficial owners.

That’s basically where the controlling interest requirements are supposed to go but it is generally considered that it doesn’t quite get there. However, it does a much better job than the proposals for a national company register in the USA but that’s a topic for another day.

So, having set the background, one thing is clear as we look through the sections: much of the Bill is not about financial or economic crime: it is about registers of ownership and control of companies and other assets.

But there are financial crime aspects: there is an attempt to fix the unsuccessful Unexplained Wealth Orders regime, there are revisions to the sanctions regime. As I said earlier, we aren’t going to look at those today.


The first part of the Bill should be independent of the rest. It should be in a Registration of Companies and Business Entities Bill. Given that it has been said that there will be a second Bill to further revise policies and procedures at Companies House, it would make far more sense to do a short sharp Bill now and then to subsume it into the later Bill and repeal the short one done now.

But simplicity is not the hallmark of recent British legislative drafting. And clarity has long been abandoned.

For example, there is no comprehensive definitions section: often, definitions are set out where terms are first used which is absolutely no help at all to those who dip into a Bill (or an Act) at a later point. It would be wrong to say that there is not a definitions section at all: Schedule Two provides a number of definitions. We’ll look at some of those later because they are not always clear or helpful. Part One also has its own ″interpretations″ section about which more later.

The very first section is a surprise to those of us who operate internationally. It is usual across much of the world for foreign owned businesses to have to register. Why is the Bill starting with ″Registration of Overseas Entities″?

The position is misleading: in fact, a foreign business operating in the UK must register with Companies House and pay a fee of 20 pounds. But Companies House says… ″If an overseas company is carrying on business in the UK, it does not automatically mean that it must register with Companies House.

You only need to register an overseas company when it has some degree of physical presence in the UK, such as a place of business or branch, where it carries on business.″
Owning property is not, it seems, considered being in business, even though there are tax implications.

So the Bill seeks to address this.

In fact, it’s an extension of the beneficial owners registration coupled with a requirement to register ″if they own land.″ That’s going to involve some fancy footwork on definitions at some point. We’ll see.

But first we have to get past the fact that the definition of ″overseas entity″ is flawed.

Seriously, one has to wonder if those drawing legislation have any legal training at all. Or training in grammar which, after all, is at the heart of effective written communication. It says ″

″legal entity” means a body corporate, partnership or other entity that (in each case) is a legal person under the law by which it is governed.″

A partnership is not a legal person in English law. The clause appears to be implying that, because the Bill relates to foreign businesses that, where partnerships are registered as a person, they are included.

If that is its intent, then it works. But it would be nice not to have to guess.

The funniest part of this is that the word ″entity″ is bandied about but is not at any point defined other than where it is qualified ″an overseas entity is a legal entity…..″

And no, ″legal entity″ is not defined either.

The second funniest part is that, in the definitions section (Schedule 2), the Bill does recognise that a partnership is not a legal person. So the draftsmen can’t even manage consistency in their own Bill.

The Bill says ″The registrar of companies for England and Wales (“the registrar”) must keep a register of overseas entities in accordance with this Part.″

But in its webpage about registering overseas companies in the UK, updated on only 31 December 2020, Gov.UK says ″A UK establishment is a place of business or branch of an overseas company in the UK.

When registering a UK establishment of an overseas company, the UK is treated as a single jurisdiction.
All places of business and branches registered before 1 October 2009 have become UK establishments and given a ‘BR’ prefix to their registered number.″
The link is in the notes at the of this article.

And then there is another fundamental failure to understand the subject.

″A statement that the entity has no reasonable cause to believe that it has any registrable beneficial owners.″

No. that is impossible. It is impossible because it requires a corporation to have a state of mind and corporations, it is long settled law, cannot form a state of mind.

This those writing the Bill would have known if they had had suitable training for example the Financial Crime Risks of Corporations, Trusts and other business structures at Financial Crime Risk and Compliance Training (there’s a link below).

There are other places where the same mistake is made.

Let’s flick to the Definitions section. It’s in Schedule 2 and if you have the version of the Bill I’m using (it might have been re-positioned as amendments are made) it starts on page 37.

I’m going to leave you to read the garbled text in the Bill and I’m going to put it into plain English for you, or rather I’m going to put it into plain English that I hope is what the draftsmen were trying to say.

A registrable beneficial owner is a legal or natural person or group of persons or a government or public authority or other structure authorised under the laws of its home jurisdiction.

That’s all that’s needed, not the page-long ramblings that are in the Bill.

Note that the Bill says ″may be″ but that’s silly. For clarity there must be certainty: there is no room for flexibility.

So, note this: it includes – as it should – government-linked companies and companies owned by sovereign wealth funds.

But, of course, nothing is ever that simple.

You will note the phrase ″is not exempt from being registered (see Part 4)″. This is part not clause. So we have to scroll down to page 39 where we find a chunk of text headed ″Beneficial Owner Exempt from Registration.″

Yes, you can have a ″hang on a minute″ moment. Are we going to find out that there is a simple, even brutal system and then there are going to be loopholes set into the law?

Well, yes. That’s exactly what we are going to find.

See if you can pick out the logic in this statement:

″a person who is a beneficial owner of an overseas entity is “exempt from being registered” if—
(a) the person does not hold any interest in the overseas entity other than through one or more legal entities″

Let’s have an example: A holds 100% of the shares in B, a foreign company, which holds more than 25% of the shares in C which is registering in the UK as an overseas entity. A does not hold shares in C. Prima facie, A does not have to be registered. That is in complete contradiction to the basic principles of identifying the ultimate beneficial owner in order to prevent the anonymisation of ownership through the use of nested corporations.

Another exemption is this ″the person is a beneficial owner of every legal entity through which the person holds an interest.″

Perhaps it’s time to look at the definition of ″beneficial owner.″

Again, the draftsman seems to be operating in a vacuum, conveniently ignoring the fact that the term ″beneficial owner″ has long had a very specific meaning in English law and it’s not what is now being said. Once more, confusion not clarity seems to be the purpose of the drafting of British legislation.

Indeed, it is so confused that even the British government doesn’t understand it. In a media release announcing the Bill, it says the Bill will ″ensure criminals cannot hide behind secretive chains of shell companies, setting a new global standard for transparency.″

Do you want a break while you laugh?

In the context of this Bill, then, but not otherwise, the term ″beneficial owner″ means

a) a person who owns or controls more than 25% of the shares and/or voting rights in a company;
b) directly or indirectly has the authority to appoint or remove a majority of the board of directors of the company
c) has the right to exercise or in fact exercises significant influence or control over the company.

It follows, then, that shadow directors are included under c, that ″activist shareholders″ who use a small percentage of shares to stir up trouble but which need the support of other shareholders to remove the board are not included under b) and that the percentages are consistent with the Know Your Customer guidelines in many countries (but which, incidentally, I have always argued is too generous and we should be taking a figure for KYC purposes of 10%).

Note that nothing in this provision refers to shareholders acting in concert. So two family members who, collectively, have more than the threshold are not registered.

There is a further ″condition″ to be met in respect of beneficial owners and it relates to trusts, unincorporated associations and partnerships. It is difficult to see how these structures are not automatically included in the definition above. It refers to ″trustees of a trust or the members of a partnership, unincorporated association or other entity that is not a legal person under the law by which it is governed...and such person has the right to exercise or does in fact exercise, significant influence over the activities of that trust or entity.″

So now we have another inconsistency: previously there was reference to partnerships, for example, as legal persons under the law in their home jurisdiction.

Now the Bill talks about partnerships which are not legal persons under their home jurisdiction and granting them exemption.

Is it an inconsistency or a major loophole?

These are the very persons that are the subject of Know Your Customer details for account opening at any regulated financial institution. And they are, either, legal or natural persons and therefore there is no reason for this final ″condition″.

In fact, what is clear is that whoever drafted this law did not co-ordinate it with the guidance issued by the relevant government departments or regulators in relation to account opening under counter-money laundering laws and regulations.

I recommend you read the requirements set out in Part 1 of Schedule 1: you will see that they are, essentially, the KYC information that banks, etc. are required to collect but that the wording is different to that set out in Regulations and Guidance Notes. That’s just stupid, in my view. The same stuff should have the same terminology or else everything becomes a muddle.

We still don’t know what an ″entity″ is, by the way.

I can’t go into detail of every word in every line of the Bill or we’d be here until Christmas. I will say that the issues raised above are replicated, over and over again, throughout Part 1 of the Bill. You will see this when you read through it.

However, there are some particular things that deserve individual spotlights.

″3.3 The list of registered overseas entities must contain the name of each overseas
entity that—
(a) has made an application for registration in accordance with the
requirements of this Part (see section 4), and
(b) has not been removed from the list under section 10.″

″10 (5) Where an overseas entity is removed from the list of registered overseas
entities, the registrar must record the date of removal in the register.″

So, an application to be removed from the register does not remove the registered company because there remains an entry as to the date of removal. It is absolutely right that there should be a history of registered companies and the dates of registration and, even, of the information that was current during registration – just as there is in relation to e.g. dissolved UK companies.

It is ridiculous that a) it’s called removal when it’s not removed and b) that there is a different standard applied to that for UK registered companies which undermines the value of the register for future inquiry.

Also, after two years, the ″removal″ does take place, if the Registrar chooses. But it doesn’t disappear – it just gets transferred to the Public Record Office so that’s just another database to search for KYC purposes. Genius, not. It should be treated in exactly the same way as dissolved companies are treated – and for that there is an established system that works.

There are defined processes. Take a look at clause 20, for example. It is highly prescriptive.

It is unusual for such material to be included in primary legislation in the UK: usually it is included in Regulations.

These are secondary legislation also known as statutory instruments. The reason for this is that Regulations are more flexible than primary legislation or Acts. Acts usually delegate authority to a government department or agency which is required to conduct itself as the Regulations set out. But there is another aspect: for example the Money Laundering Regulations (in all their various forms and names) exist under the auspices of HM Treasury which is empowered under the Act to make and modify those regulations.

They do go through a parliamentary approvals process but they are not, usually, debated in either the House of Commons or the House of Lords.

To include these detailed provisions within the Act is therefore a departure from the usual form of legislation in the UK, particularly England and Wales.

Internationally, to include them in primary law is far from unique but it is, in some ways, a retrograde step as it locks in processes that should be flexible. It has to be said that, despite the prescriptive approach in the Bill, it does mention ″regulations made under″ it so there is clearly an intention to have secondary legislation for some purposes.

Anyway, that’s another black mark against this Bill.

What should have happened is that the Bill should have been simplified and the detailed processes should have been put forward by the relevant Government department included in a separate set of, for example, Companies Registration Regulations.

In the UK, the relevant department used to be known as The Department of Trade and Industry and it had a cute little logo incorporating its initials.

But in 2005 the Department of Trade and Industry was rebranded as the Department for Productivity, Energy and Industry and in 2007 that was replaced by the Department for Innovation, Universities and Skills and the Department for Business, Enterprise and Regulatory Reform. ″ That can all be laid at the door of those masters of obfuscation Tony Blair and Gordon Brown.

Over the years, those two departments with names so unloved and acronyms so despised (one even looked like someone couldn’t spell ″beer″) have gone in and out of mergers and divisions.

There was a good one: the Department of Business, Innovation and Skills : except that its initials were an acronym in widespread use around the world, it was at least simple.

But that didn’t last and BIS was merged with the Department of Energy and Climate Change (DECC) have merged to form the Department for Business, Energy and Industrial Strategy (BEIS).

I tell you this because we need to know which department Companies House – and therefore registrations - would fall under if it were to be handled in the standard way. The answer is that, throughout it all, the regulation of companies has always landed under whatever Department had ″business″ in its name. So we are just going to take the easy way out and call the relevant department ″The Department of Business.″

Why does this matter? It’s simply because authority for at least a portion of Companies House’s activities is now under the Home Office, which sponsors this Bill, and the rest is under the Department of Business, etc.

So, who is supposed to be in charge?

The answer is that there is no single department in charge.

Section 21 is good – on the surface: the register, like the register of companies, is to be an open register with certain limitations primarily related to personal security. Simply being rich is not, at least in theory, supposed to be a reason to keep information confidential.

But…. there are degrees of ″open″ and this might not be as open as first appears. Any person is able to ″inspect″ the register – that does not mean it is going to be a universally accessible register. Secondly, there is a right to obtain a copy – but that right is not absolute. The Registrar will specify the ″form and manner″ of the application – and in which copies will be provided. Will it be an open register accessible over the ‘web as is the Companies Register – and if not, why not?

If the purpose of the register is to help in identifying suspicious activity, then why is the government saying that access might be restricted?

Section 22 lists material that is ″unavailable for inspection.″

Mostly, there is nothing to complain about except this:

″residential address information is “protected” if—

(a) it relates to an individual who, at the time the information is delivered to the registrar, is a registrable beneficial owner or managing officer in relation to an overseas entity,″

If the information is required, and is public as it is for British registered companies then how is it right that it should not be provided for foreign registered companies?

How does blocking it help financial institutions undertake effective Know Your Customer or, even, assess the risk rating for e.g. a counterparty? This is a fundamental failure of a hugely important prospect for the financial crime risk and compliance officers across the entire financial and commercial landscape.

The perspective of this BLOG/cast has been from that of Financial Crime Risk Officers in UK institutions and, largely, how the provisions in the Bill fail them or make their lives more complex.

But for a few minutes, I want to turn to look at a couple of provisions from the point of view of the entity that is making the registration.

I’m not going to list the information that must be provided: you can read that in the Bill. We’re going to start at section 31 on page 18.

It says ″It is an offence for a person knowingly or recklessly to deliver or cause to be delivered….. any document that is misleading, false or deceptive in a material particular″

I’ve already explained that a company cannot form a state of mind. Companies can only be liable for offences of strict liability or where a Court is satisfied that it was directed to undertake a course of conduct by its officers.

So it is impossible for a company to knowingly or recklessly deliver. However, companies do in fact lodge forms, applications and the like all the time. Companies are deemed to make statements when their seal, for example, is affixed even though the company per se does not form an intention.

The ″knowingly or recklessly″ can only refer to the individual who submits the form; in this way there is personal responsibility on the officers of those agents or companies that submit forms.

This view is reinforced by the penalties: it’s jail and/or a fine. Companies can’t be jailed. The penalties in inferior courts in England and Wales are according to the general sentencing guidelines. In Northern Ireland the jail sentence is up to six months and in Scotland up to 12 months. On indictment, the penalty across the UK is jail of a maximum two years and/or a fine.

The next point I want to turn to is the register of land ownership and land transactions by overseas entities. This has caused some consternation in certain quarters in the UK with arguments that the implementation provisions are effectively an invitation to the real targets (kleptocrats and oligarchs) to divest themselves of property before registration is required.

But there has to be a practical time-frame.

A Conservative back bencher in the debate this week had a good idea: why not just refuse to register those transactions suspected of relating to the targets. It’s a good idea but it relies on someone identifying the targets – there is no space on a land registry form for someone to tick ″this transaction involves an oligarch″ or some such.

The time period for making the application to register is six months and it will require retrospective action i.e. the registration of property which is already owned by an overseas entity.

The power of this section should not be overlooked – while the stated target is Russian oligarchs and their mates, the effect is global.

All UK property owned by foreign companies and trusts must be registered as such.

Foreign includes EU, USA, Australia and, of course, all those in so-called offshore centres.

The Bill will provide line-of-sight into companies registered in so-called confidentiality or secrecy jurisdictions in a way that has, so far, not been possible.

This will greatly please those who agitate for tax reform and who are open about their objective of global tax harmonisation. We should expect to see more countries imposing similar measures in coming years.

If we cross-refer that to the exemptions from registration and we find government owned companies, the ownership of huge swathes of the UK by sovereign wealth funds and, for example, Arab rulers, will not be registerable, even if they do so through a foreign company.

So that’s not very effective, is it?

Penalties are against the entity and ″every officer of the entity who is in default.″

That’s the way to do it, not to try to make a company have a state of mind as shown above.

Sentences are similar to those for filing misleading documents.

″Officers″ are directors not Company Secretaries who have no voting rights. No mention is made of non-executive directors.

It also means ″a person in accordance with whose directions or instructions the board or equivalent management body is (it says ″are) accustomed to act″ (excluding professional advisers). So that’s shadow directors and those who have a controlling interest as well as silent but powerful persons. Quite why this doesn’t adopt the wording described earlier is a mystery.

But here’s the rub: proceedings are not permitted without the authority of the Director of Public Prosecutions. So it is open to influence in a way that a purely regulatory offence should not be. It’s like needing the DPP to approve a prosecution for driving without a licence.

Now let’s take a look at the registration of ″land″ ownership by a foreign company.

You will remember that I said that the Act would have to contain some pretty fancy footwork if the term ″land″ was to be used and so it does. We’ll get to that in a moment.

For now we’ll look at sections 32 and 33. I’ll also say now rather than later that the penalties for false or late, etc. registrations and updates is as previously set out.

Section 32 is at page 18. But it is basically a signpost to several Schedules which amend the Land Registration Act which operates differently depending on which UK jurisdiction the land is in. There is a special provision that Regulations (i.e. statutory instruments) made under Section 32(4) are subject to what it termed, in the Bill, the affirmative resolution procedure. That’s confusing because the UK Parliament website, which we can consider the proper authority, refers to ″Affirmative procedure.″ So, once more, the draftsmen have caused confusion by lack of attention. The ″affirmative procedure″ requires that both the House of Commons and the House of Lords actively approve the Regulations. Some Regulations relating to financial matters require approval by only the House of Commons.

Before going all the way to Schedule Two, let’s quickly see what’s in Section 33.

This section gives the power to the Secretary of State (which in this case means the Home Secretary because this is a Home Office sponsored Bill) to require, by notice, an overseas entity to register in the registration of overseas entities if the entity is registered as the proprietor (owner) of a relevant interest in land provided that there is no current registration, no application pending and that it is not an exempt overseas entity. There is six month time limit. The notice lapses if the entity ″ceases to be registered as the proprietor.″

It is this clause that criticism of the six months period is justified. It should be six weeks or perhaps even 28 days. The only reason for the notice is that there is suspicion that a registration has not been effected.

If we apply the principles of e.g. counter-money laundering law, then such a notice should trigger an immediate freeze on the transfer of the asset until the register is complete. This would be effected by a direction to the Land Registry that no transfer should be registered. As the Land Registry is, in the absence of error, the sole authority as to ownership of certain types of property, this effectively makes it impossible to transfer ownership.

And now it’s time for the definition of ″land.″

As you might imagine, it doesn’t mean only ″land.″ It is a freehold or leasehold interest (such lease being for a minimum of 21 years). That might be in land but equally it might be a flat or an office in a tower block.
It does not cover all the possibilities for registration of title.

I’m not going to go into this: if it interests you take a look at the Land Registration Act 2002 which, in the first couple of sections, lists the types of interest in land that can be registered.

Where there are ″joint interests″ (I think that means ″joint tenants″), then each is treated for the purpose of the Bill as holding the entire property and therefore liable as such.

In the case of ″joint arrangements″ (which I think means tenants in common) then each is treated as holding, and therefore liable for, that division which the arrangement provides for.

There is a definition of ″arrangement″) at clause 12 (3) and (4) of Schedule Two, something that would be completely unnecessary if the established terms had been used.

There is also provision for calculating shareholdings. It makes no reference to parties holding shares in concert. Nor does the following clause about voting rights (13 and 14)

Shares held by a nominee are to to be counted as shares held by the principal (which is consistent with the ultimate beneficial owner principle).

That’s pretty much all I need to say about Part 1 that isn’t reasonably clear on the face of the Bill except to say that at s39 there is an interpretation section which is the third location for definitions. It’s on page 21. In this case, the definitions apply only to part 1 so, if the same term is used in Parts 2, 3 and 4, they might not mean the same.

And still there is no definition of ″entity.″

There is provision for Regulations to be laid which will provide for financial (civil not criminal) penalties and for the proceeds to be paid into the ″Consolidated Fund″ which means the money pit managed by the Treasury.

That’s it for this BLOG/cast. If you found it valuable and/or interesting you can thank me via HonourPay (click the link on this page).

Be happy, safe and well

Thanks for listening.

I’ll talk to you next time.




House of Commons Debate should appear here:…


Companies House – registration of foreign businesses :…


UK Department for companies:…

House of Commons glossary:…

Land Registration Act 2002


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