File 00 / Summary

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

AreaWhat to establish
Legal identityVerify the company's legal name and registration details
AddressesConfirm the registered office and principal business address
Business activityUnderstand the nature and purpose of the business and the relationship
DirectorsIdentify and verify relevant directors and authorised representatives
OwnershipEstablish the ownership and control structure
Beneficial ownersIdentify 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 accepted Escalate: more information, EDD or management sign-off Decline: 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.

Ama Owusu Kojo Asare Daniel Mensah Meridian Holdings Ltd Sterling Capital Services Ltd 60%40% 70%30%
IndividualCalculationResult
Ama Owusu70% × 60%42% indirect
Kojo Asare70% × 40%28% indirect
Daniel Mensahdirect30% 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.

FindingRatingRecommended action
Incomplete beneficial ownership recordsHighReview affected files and obtain the missing information
No formal log of internal suspicious activity escalationsHighSet up a restricted-access escalation and case register
Risk assessments not consistently documentedMediumIntroduce a standard risk assessment template
No documented periodic review processMediumSet risk-based customer review schedules
Weak evidence of compliance trainingMediumKeep training records and run refreshers

Corrective action plan

ActionOwnerTarget
Set up internal escalation registerMLRO / Compliance14 days
Remediate incomplete customer filesOperations / Compliance30 days
Introduce standard risk assessmentsCompliance30 days
Introduce training recordsHR / Compliance30 days
Establish customer review schedulesCompliance / Operations45 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.

File 03 / Credentials

Qualifications and membership

  • Affiliate Member

    Chartered Governance Institute UK & Ireland
  • LLM

    University of East London, in progress
  • ICA Certificate in Anti Money Laundering

    In progress
  • BA Business Management Studies

    University of Cape Coast, Ghana
  • HND Accounting

    Accra Technical University, Ghana
  • Advanced Cyber Security: Threats and Governance

    Great Learning, certificate of completion