Registry Initiatives

1. Welcome to
ECRF | CRF
CONFERENCE
Cardiff UK | 2016

2. Registry Initiatives
Helping law enforcement to combat fraud
and improving compliance
Stuart Morgan
Integrity Unit, Companies House

3. About Companies House
• Registry not a regulator
– receives information
– makes it accessible
– available for free
• Enforcement role
– Non-compliance
– Late filing penalties
– Prosecution

4. Deterrence and remedies
Problem
• 2,000 complaints a year relating to unauthorised
use of addresses for Registered Office Address
(ROA) and bogus appointments
Action
• Introduction of ROA and Director disputes
legislation commenced 6th April, 2016
Results
• Combatting corporate hijack with:
o Power to move registered office to default
address at CH
o Power to remove details of appointment where
person did not consent

5. Work with law enforcement
• Prior to 2014 received an average of 10 requests per
month from law enforcement agencies (LEA)
• Integrity Unit was established in April, 2014
• To support the combat of economic crime and fraud
the Integrity Unit joined GAIN
• LEA interested in data that sits behind the scenes
• Receive 140 requests from LEA every month
• Provide bespoke analysis for investigations

6. Examples / case studies
HMRC Supported investigations relating to VAT fraud
DWP
Helped combat economic crime relating to pension
fraud
Insolvency
Service
Supported investigations relating to short firm fraud
and bogus limited companies
Police
A source of intelligence relating to criminal activity by
directors

7. Improving compliance
• Companies House prosecute on behalf of the Secretary of State for
non-filing of accounts and annual returns (confirmation statement)
• We promote compliance by:
– e-mailing and sending paper reminders
– effective compliance process – UK soft compliance 99.1%*
Accounts 98.3%* Annual Returns
– imposing a late filing penalty regime, which issued 178,885* UK
penalties for companies filing accounts late totalling £84*
million
– 2,009 UK directors prosecuted for non-filing offences

8. Improving compliance
• We improve non-compliance by working with LEA’s and Other
Government Departments (OGD)
• FTSE 350 compliance - S409 disclosure of subsidiary undertakings
• Natural person Director compliance:
– over 5,000 companies without natural person directors
– primarily corporate directors
– working closely with BIS prosecutors
– improved to over 98% compliance

9. Disqualified directors
• Companies House maintains register of disqualified directors on
behalf of the Secretary of State.
Problem
• Disqualifications notified to Secretary of State –
1,227 (including 899 by undertaking) analysis
indicated level of under reporting of
disqualifications by 10%.
Remedies
• Data matching with Insolvency Services
• Introduced compliance actions
• Companies House working with Ministry of Justice

10. New challenges
• UK introducing first open register of beneficial ownership or
persons of significant control
• Year to populate register, with introduction of systems to identify
non-compliance
• Companies House working across government and law
enforcement to establish an effective compliance and enforcement
regime.
• Working with civil society to help identify non-compliance