The purpose of the alert is to outline an emerging threat relating to the misuse of registered offices.
What is happening?
A cuckoo is known for laying its eggs in the nests of other birds. Fraudsters appear to have adopted this practice for their own benefit, using the address of an accountancy firm as the registered address for companies they have established.
The accountancy professional body supervisors have identified that this could be a wider problem than previously thought. Not only has this issue been identified at supervisory visits, but a straw poll of a variety of larger and mid-size firms indicates that all of those have found cases of companies using the firm’s address without their knowledge or authorisation.
There could be some innocent errors in the cases identified, but the most likely explanation for using the accountancy firm’s address is that it provides credibility, which may be used to facilitate fraud.
What can you do?
Identifying the misuse of the address is relatively easy. The quickest way is to input the firm’s postcode in the search box on the Companies House website, which will bring up the names of all those who are registered at the address (filter for companies rather than 'all').
We recommend that firms check to see which companies use their address as a registered office. If you do not recognise a name, and this is not because of a name change or the registration of a new subsidiary of an existing client, the firm should try to have the record changed.
If there are contact details (other than the registered address), it would be worth contacting the company requesting that they change their registered address to a more appropriate one.
In other cases, you should approach Companies House to ask for the address to be changed; this would then go to a default, Companies House address.
Suspicious activity reporting (SARs)
If you know or suspect money laundering or terrorist financing activity, you should make a SAR using any relevant glossary codes.
Data protection considerations
Please consider your obligations under the relevant data protection regulations and, where, necessary remove any related personal data from your systems securely and within a satisfactory timeframe.
Disclaimer: The Accountancy AML Supervisors’ Group accepts no responsibility for any loss, damage or expense arising in connection with the use of information in this alert. Any use will be taken to signify agreement to these conditions.