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Introduction to this document

PSC checklist

All companies must keep a register of people who have significant control over them. Use our checklist to make sure you have taken the required steps to identify the right people.

What is a PSC?

A “person with significant control” basically means someone capable of influencing the company’s decisions, usually through their shareholding. However, the definition is broad and deliberately designed to include those with less obvious forms of control and influence.

All companies have to keep a register of their PSCs in the interests of corporate transparency. The register was introduced to stop people using beneficial ownership of shares to mask criminal activities like money laundering (because someone else’s name is on the register of shareholders instead of their own). The register of PSCs helps to ensure that those who control a company’s activities in reality can be traced by the authorities if necessary, as well as enabling those who deal with the company to find out exactly who they are doing business with.

How to identify PSCs

There is a process that companies need to follow to find out who their PSCs are. This should be kept under review as the company is obliged to keep its register and the one at Companies House up to date. PSCs are also obliged to inform the company of any changes to their registered information, or if they believe they should be included on the register.

The register of PSCs needs to be updated during the investigation process and with the PSC’s details once they have been obtained/confirmed.