About this form
Form U4 records a legal person or legal arrangement that an unrepresented counterparty is acting on behalf of. As with Form A4 on the client side, it also covers the estate of a deceased person where an unrepresented executor is transacting.
When you need it
- An unrepresented counterparty acts for a company, partnership or trust.
- The unrepresented counterparty is an executor and the estate’s beneficiaries need to be recorded.
- A representative on the other side is transacting for an entity that is not itself the counterparty.
How to complete it
- Complete the counterparty’s own particulars form first. For an estate, the executor completes U1.
- Record the legal person or arrangement on U4, including the individuals behind it.
- Verify the counterparty’s authority to act — for an estate, the grant appointing the executor.
- Complete a Form U5 for every person screened.
Common mistakes
- Recording the executor and not the beneficiaries.
- Using U4 where the principal is an individual — that is U3.
- Applying a lighter standard than would be applied to a client in the same position.
- Screening only the person in front of you.
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 unrepresented estate handled?
- The executor completes the individual counterparty form, and the estate is recorded on U4 as a legal arrangement, which captures the beneficiaries.
- Is U4 used instead of U1 or U2?
- No — in addition. The counterparty’s own particulars form comes first.
- 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.