About this form
Form U2 is the entity version of the unrepresented counterparty particulars form — the counterpart to Form A2 on the other side of the transaction. It carries the same beneficial-ownership and authority obligations as A2, applied to a party who is not your client.
When you need it
- The unrepresented other side is a company, partnership or similar entity.
- The counterparty is a legal arrangement such as a trust.
- A corporate seller or landlord is transacting without an agent.
How to complete it
- Confirm the counterparty is genuinely unrepresented before starting.
- Record the entity’s particulars and verify its existence.
- Identify and verify the beneficial owners.
- Verify the representative’s identity and their authority to act — both, separately.
- Complete a Form U5 for every person screened on that side.
Common mistakes
- Applying a lighter standard to a counterparty than to a client. The entity obligations are the same.
- Stopping at the entity without reaching its beneficial owners.
- Verifying identity but not authority.
- Completing one U5 rather than one per person screened.
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
- Does an unrepresented corporate counterparty need beneficial owner checks?
- Yes. Identifying the individuals who ultimately own or control the entity applies on the counterparty side as it does for a client.
- What if the counterparty refuses to provide particulars?
- Due diligence has to be complete before the agreement is entered into. Where it cannot be completed, the transaction should not proceed — escalate to the Compliance Officer.
- 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.