About this form
Form A4 is the companion to A3 for cases where the party your client acts on behalf of is a legal person or a legal arrangement rather than an individual. It also covers the estate of a deceased person, which is where most salespersons meet it in practice.
When you need it
- Your client is acting on behalf of a company, partnership or trust.
- Your client is the executor of an estate — A4 records the estate as a legal arrangement and captures the beneficiaries.
- A representative is transacting for an entity that is not itself your client.
How to complete it
- Complete the client’s own particulars form first. For an estate, the executor completes A1 as the individual client.
- Record the legal person or arrangement on A4, including the individuals behind it — beneficial owners for an entity, beneficiaries for an estate.
- Verify the client’s authority to act, which for an estate means the grant appointing the executor.
- Complete a Form B for every person screened.
Common mistakes
- Treating an estate as though the executor were transacting for themselves, so the beneficiaries never reach the file.
- Using A4 where the principal is an individual — that is A3.
- Recording the entity without identifying the individuals behind it.
- Screening only the executor.
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
- How is an estate handled?
- The executor is the client and completes the individual form. The estate is treated as a legal arrangement and recorded on A4, which is what brings the beneficiaries onto the file.
- Is A4 used instead of A1 or A2?
- No — always in addition. The client’s own particulars form is completed first, and A4 sits alongside it.
- 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.