About this form
Form U5 is the counterparty equivalent of Form B: screening results and a recorded risk conclusion for the unrepresented side of a transaction. Like Form B, it is completed for every person screened, not once per counterparty.
When you need it
- Any transaction with an unrepresented counterparty that is not an exempt wholly residential HDB rental.
- Once for each person screened on that side — the counterparty, its beneficial owners, and any principal.
- Where a new party appears on the unrepresented side part-way through.
How to complete it
- Screen against the TSOFA, UN, FATF and CEA lists, and check for politically exposed person status.
- Capture the screening evidence rather than only the outcome.
- Work through the red-flag checklist and record a genuine conclusion.
- Where the conclusion is higher risk, complete Form U6 and obtain the Compliance Officer’s prior approval.
Common mistakes
- Completing one U5 for the counterparty side rather than one per person screened.
- Doing counterparty screening at all in a co-broke transaction, where it is not required.
- Recording an outcome with no supporting evidence.
- Identifying higher risk and proceeding without approval.
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 many U5 forms are needed?
- One for every person screened on the unrepresented side, in the same way Form B works on the client side.
- Why does CEA’s Form U5 contain an insecure link?
- The copy of Form U5 published in CEA’s compendium contains an http link to an external reporting site. It is CEA’s document and is reproduced here exactly as issued — correcting a regulator’s form would be a worse outcome than the link. Our own document audit records it as a review item for that reason.
- 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.