1 August marks the first anniversary of the inception of the Register of Overseas Entities (ROE) and the start of an updating requirement for Overseas Entities (OE) depending on when they registered on the ROE.
OEs must file an update statement within 14 days of the 12 month anniversary of their registration on the ROE. The statutorily prescribed update statements will, broadly, confirm that all the information about that OE on the ROE is still correct or update any information that has changed since registration. Where any changes have occurred, they will need to be verified by an independent agent. An update statement must be filed even if there are no changes to report (although the administrative burden can be reduced by referring to previously supplied information).
Failure to comply with this requirement will result in the OE not being treated as a registered OE (which will impact on its ability to deal with its property) and could result in criminal or financial penalties until the updating obligation is complied with.
It is possible to file an update statement online at Companies House, unless there are any trusts involved in the OE, in which case the update statement must be filed on paper.
More detail about what you will need to file an update statement online is available on the government's website here.
OEs should also be aware of the Economic Crime and Corporate Transparency Bill which is currently making its way through Parliament. The Bill seeks to further increase transparency and tackle economic crime by addressing concerns around the updating requirement and ownership of OEs by nominee companies. We will provide an update when further information is available.