United Nations (UN) sanctions have led to extra checks on applications to register some corporate bodies.
The United Nations imposes financial sanctions on individuals and corporate bodies because of the nature of their activities, such as genocide and terrorism. These individuals and corporate bodies are called ‘designated persons’ (DPs). The UN sanctions are included in EU and UK law to stop DPs using “economic resources”, which include companies, for those types of activities. There are penalties for breaking that law.
If you form a corporate body with a DP in the corporate structure, it would constitute making an economic resource available. It could also expose the Registrar of Companies to prosecution, because of our role in the registration process.
As an example, here’s a list of DPs in Afghanistan who are subject to sanctions. Further down that page is the EU and UK law, and other information from HM Treasury.
You can also access the online consolidated list of all DPs.
New Application Checks
With effect from 12th December 2018 we’ll check the details of proposed directors, secretaries, members, people with significant control, for any matches to a DP in an application to register:
• UK companies (private, public, limited, unlimited, limited by shares, limited by guarantee)
• European companies, known as societas Europaea (SEs)
• limited liability partnerships
• Scottish limited partnerships
We’ll look at:
• the person’s full name
• address information
• date of birth
• nationality and occupation
• main activities of the company (from the accounts or SIC code)
If we believe these details sufficiently match those of a DP, we’ll reject your application and tell you why. You’ll have the option to resubmit your application with evidence that the person is not a DP.
The type of information that might support their case could include:
• personal details on their passport
• driver’s licence
• birth certificate or other similar information
• proof of their residential address (such as a utility bill, freehold or leasehold document) and how long they’ve lived there
• proof of how long they’ve lived in a particular place
• any other personal information they want us to consider
We’ll consider this information and decide if we can accept your application.
We’ll keep all personal data strictly in accordance with the Data Protection Act 2018 and General Data Protection Regulation. We’ll dispose of this data securely, as soon as it’s no longer needed.
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