About this form
Form A2 is the customer particulars form for a client that is an entity or a legal arrangement rather than a natural person. It carries an obligation the individual form does not: identifying the people who ultimately own or control the entity, and confirming that whoever signs on its behalf is authorised to do so.
When you need it
- Your client is a company, partnership, association or similar entity.
- Your client is a legal arrangement such as a trust.
- A corporate buyer, seller, landlord or tenant is instructing you directly.
How to complete it
- Record the entity’s particulars and verify its existence from a reliable source.
- Identify and verify the beneficial owners — the individuals who ultimately own or control it. This is the part most often left incomplete.
- Verify the representative’s identity AND their authority to act for the entity. Those are two separate checks and both are required.
- Complete a Form B for every person screened, which on an entity file means the entity, each beneficial owner and the representative.
- Where the entity is itself acting for another party, add Form A3 or A4.
Common mistakes
- Verifying the representative’s identity but not their authority.
- Recording the entity and stopping there, without reaching the beneficial owners behind it.
- Filing a single Form B for the entity when one is required for every person screened.
- Accepting a corporate structure as too complex to unwind rather than escalating it as a risk indicator.
Legal basis
Published by CEA as an annex to the Guide on the Estate Agents (Prevention of Money Laundering and Financing of Terrorism) Regulations 2021. Read the issuer’s guidance.
Questions
- Who counts as a beneficial owner?
- The individuals who ultimately own or control the entity. Where ownership runs through further entities, the chain has to be followed to the natural persons at the end of it.
- What if the ownership chain cannot be established?
- That is itself a risk indicator rather than a reason to proceed. Escalate to the Compliance Officer; where due diligence cannot be completed, the transaction should not proceed.
- When must it be completed?
- All due diligence must be complete BEFORE the client enters into any agreement — before an Option to Purchase is issued or exercised, and before a Tenancy Agreement is signed.