The ROE was introduced under the Economic Crime (Transparency and Enforcement) Act 2022 on 1 August 2022. The ROE requires anonymous foreign owners of UK property to reveal their identities. Anonymous foreign owners of UK property must reveal their identities in order to buy and sell land or property in the UK. Ownership and control must be verified.

The Law Society has issued extensive guidance, Register of overseas entities: what solicitors should know about verification. It identifies significant risks and advises –

‘There should be no presumption that law firms will conduct verification for ROE purposes. It is anticipated that many firms will not conduct ROE verification. It is also recognised that for many firms it will not be appropriate to conduct ROE verification.’

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