I check who people and companies say they are, and I flag what doesn’t add up.
Over five years in corporate due diligence, regulatory compliance and governance. I give decision-makers the facts on who they are dealing with, who ultimately owns or controls an organisation, and the risks in that relationship.
For fintech clients, I vetted shareholders, directors and incoming chief executives against Bank of Ghana fit-and-proper and corporate governance requirements. I verified credentials independently with the certifying bodies, ran background and credit bureau checks, searched court records and interviewed candidates. I identified beneficial owners on every incorporation and prepared due diligence reports on shareholding structure, directors and filing history.
The Money Laundering Regulations 2017 ask the same core questions: who is the customer, who owns and controls it, and what is the risk? I answer them for UK financial services, legal and corporate compliance. The worked examples below show how.
File 01 / Experience
Where the experience comes from
Senior Associate Consultant · ES Corporate Services Ltd, Ghana
Due diligence on shareholders, directors and incoming chief executives for fintech clients against Bank of Ghana fit-and-proper and corporate governance requirements, and company due diligence reports as a service to clients. Beneficial owner identification on every incorporation. Regular compliance audits and filing reviews. Advice to directors and senior management on obligations and corporate structures, including a blue carbon project and a linked community NGO with shareholders in the UK, Germany and Ghana. Incorporations, dissolutions, policy revisions and training for boards and staff.
Associate · S.C.B. D Limited, Ghana
Client engagements covering company registration, governance documentation and regulatory compliance. Identified and mitigated legal and compliance risks across client portfolios.
Founder and Corporate Advisory Consultant · Black Fia Connect, Ghana (part-time)
Incorporation, compliance and corporate advisory services, including for companies with local and foreign participation.
Finance and Operations Manager · Songhai Africa / Untamed Empire, Ghana
Finances, management accounts and payroll in QuickBooks. Managed two pop-up retail stores and the events arm of the business. Led business development, including due diligence on prospective partners and on designers before onboarding them to the concept stores. Role since ended; the business continues to operate.
Volunteer Career Advisor · Passing The Baton CIC, UK
One-to-one sessions and group workshops guiding young people on career choices.
File 01A / Due diligence in practice
What I checked, and how
This is the due diligence I carried out for fintech clients in Ghana. It was built around Bank of Ghana's fit-and-proper and corporate governance requirements for shareholders, directors and key management.
Fit-and-proper vetting
Shareholders, directors and incoming chief executives, including short suitability interviews
Credentials
Qualifications confirmed directly with the certifying bodies
Background and credit
Background checks and credit bureau checks
Court searches
High Court enquiries for pending or decided cases affecting shareholdings or directorships
Board composition
Minimum regulatory numbers met without weakening governance; fitness for independent, executive and key management roles
Beneficial owners
Identified on every incorporation
Ownership thresholds
Nationality-based checks for investment-promotion (GIPC) registration and land lease entitlement
Dissolutions
Constitution reconciled with director and shareholder registers to establish who is paid
Company due diligence reports
Company details, shareholding structure, directors and filing history, brought together in a comprehensive report for the client
Partner and supplier checks
Prospective partners and designers assessed for capability and reputation before onboarding
File 02 / Work samples
How I approach UK customer due diligence
These are hypothetical exercises I wrote to show my method and my grasp of UK compliance principles. They are not work done for a UK-regulated client, and they are not legal advice. Check current rules before relying on any point.
CDD-01Corporate customer due diligence checklistOpen
Scenario: a UK-regulated financial services business is considering onboarding a new corporate customer.
1. Customer identification
Area
What to establish
Legal identity
Verify the company's legal name and registration details
Addresses
Confirm the registered office and principal business address
Business activity
Understand the nature and purpose of the business and the relationship
Directors
Identify and verify relevant directors and authorised representatives
Ownership
Establish the ownership and control structure
Beneficial owners
Identify relevant beneficial owners and verify their identities
2. Risk assessment factors
Customer: ownership complexity, PEP exposure, adverse media
Geography: countries of incorporation, operation and transaction exposure
Product: the services requested and their financial crime exposure
Delivery channel: non-face-to-face onboarding, reliance on intermediaries
Transactions: expected volumes, counterparties and patterns
3. Triggers for enhanced due diligence
Politically exposed persons, and their family members or known close associates
High-risk third-country connections
Complex or unusual ownership arrangements
Unexplained source of funds or source of wealth
4. Onboarding decision
Approve: CDD met, risk acceptedEscalate: more information, EDD or management sign-offDecline: requirements cannot be met, or outside risk appetite
Record the evidence obtained, verification results, risk rationale, open issues, approvals and review dates. Reference: Money Laundering Regulations 2017 (as amended), customer due diligence and enhanced due diligence provisions.
UBO-02Corporate structure and beneficial ownership assessmentOpen
Scenario: a fictional company, Sterling Capital Services Ltd, applies to open a business account with a UK financial institution.
Individual
Calculation
Result
Ama Owusu
70% × 60%
42% indirect
Kojo Asare
70% × 40%
28% indirect
Daniel Mensah
direct
30% direct
All three hold more than 25% and so cross the threshold used in the UK PSC framework. The control and reporting analysis must also consider voting rights and other forms of significant influence or control.
Verification still required
Verify the identity of all three individuals
Obtain ownership documents for Meridian Holdings Ltd
Check both companies' registered details and compare with Companies House records
Look for nominee arrangements, trusts or extra control rights
Confirm that the stated ownership matches actual ownership and control
Conclusion: the structure can be identified from the information supplied, but onboarding should not proceed on the percentages alone. Complete verification, establish the nature of the relationship and assess other risk factors before deciding.
Reference: Money Laundering Regulations 2017 (as amended) and the Companies Act 2006 PSC framework.
MON-03Compliance monitoring and internal controls reviewOpen
Scenario: a hypothetical review of a small financial services business finds weaknesses in onboarding and monitoring.
Finding
Rating
Recommended action
Incomplete beneficial ownership records
High
Review affected files and obtain the missing information
No formal log of internal suspicious activity escalations
High
Set up a restricted-access escalation and case register
Risk assessments not consistently documented
Medium
Introduce a standard risk assessment template
No documented periodic review process
Medium
Set risk-based customer review schedules
Weak evidence of compliance training
Medium
Keep training records and run refreshers
Corrective action plan
Action
Owner
Target
Set up internal escalation register
MLRO / Compliance
14 days
Remediate incomplete customer files
Operations / Compliance
30 days
Introduce standard risk assessments
Compliance
30 days
Introduce training records
HR / Compliance
30 days
Establish customer review schedules
Compliance / Operations
45 days
Management should see regular updates on open actions, overdue reviews, high-risk customer exposure, training completion and internal escalations. A follow-up review should test whether the fixes work.
Frameworks drawn on: Money Laundering Regulations 2017, Proceeds of Crime Act 2002, Terrorism Act 2000, Sanctions and Anti-Money Laundering Act 2018, FCA Financial Crime Guide, JMLSG guidance, and the Companies Act 2006 PSC framework.