MLR 2017 reg. 28 makes a bank identify the beneficial owner behind a corporate customer and take reasonable measures to understand the ownership and control structure. A beneficial owner, in the MLR 2017 sense, is the individual who ultimately owns or controls more than 25% of the shares or voting rights, or who otherwise exercises control. Companies Act 2006 Part 21A asks a UK company the same question for its own PSC register, and the Register of Overseas Entities under the Economic Crime (Transparency and Enforcement) Act 2022 asks it of overseas owners of UK property. Reg. 33 adds enhanced measures where the risk is higher, including the separate treatment given to politically exposed persons. The form therefore names real people at real addresses. anonym.plus marks every identifier on your machine, so the certification stays valid while those details are shielded.
When this applies
An examiner tests how the team handles layered ownership. The entity names, the percentages and the structure chart make the point. The individuals' National Insurance numbers, passport numbers and home addresses do not.
How anonym.plus handles it
- Open the certification in anonym.plus on your device.
- Local OCR reads a scanned, signed page.
- It flags each person, NINO, and ID number.
- Confirm the flags and keep the entity and share data.
- Swap or black out the confirmed identifiers.
- Save the clean form locally.
What you need to provide
- The certification (PDF, DOCX, or scan).
- An operator (Replace keeps the structure readable).
- Optional name map so one party maps to one alias.
PII & financial identifiers detected
| Category | anonym.plus entity type | Example |
|---|---|---|
| Names | PERSON | owner D. Ortiz → [OWNER_1] |
| Identifiers | UK_NINO | QQ 50 98 22 B → [NINO] |
| Identifiers | UK_PASSPORT | passport 987654321 → [PASSPORT] |
| Organization | ORGANIZATION | Helix Holdings Ltd → [ENTITY] |
| Location | LOCATION | home address → [ADDRESS] |
| Dates | DATE_TIME | DOB 1980 → [DOB] |
Compliance achieved
- Shields the individual details collected to satisfy MLR 2017 reg. 28, including the ownership-structure question.
- Handles the same people a UK company must record under Companies Act 2006 Part 21A, the PSC register.
- Covers overseas structures caught by the Register of Overseas Entities under the Economic Crime (Transparency and Enforcement) Act 2022.
- Keeps the enhanced-diligence file complete for MLR 2017 reg. 33, where higher risk applies.
- A shared name map keeps each party steady across pages; nothing is uploaded.
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Limitations & cautions
A named entity with a small share can still point to one person, because the PSC register under CA 2006 Part 21A is public and searchable. Consider masking the entity too, and keep the unredacted original for the reg. 40 retention period.
Frequently asked questions
Who counts as a beneficial owner?
For a body corporate, the MLR 2017 point at the individual who ultimately owns or controls more than 25% of the shares or voting rights, or who otherwise exercises control over the management. Reg. 28 makes you take reasonable measures to identify that person and understand the structure behind them.
Is a home address really worth hiding?
Yes. It is one of the most re-identifying fields on the form, and it is not what the public register shows — a PSC entry at Companies House carries a service address, with the usual residential address protected. A shared copy that reproduces the real address gives away more than the register does.
Is the certification uploaded?
No. The app is fully offline, so the party details stay on your device.