Since Aug 1, the Commerce Ministry has widened checks beyond initial registration to cover later changes in shareholders, directors and authorised signatories. Applicants in certain high-risk cases must now give investment details and financial evidence of the source of funds. Being flagged as high-risk does not by itself mean a company is a nominee, and foreign shareholding within legal limits does not automatically trigger action. 23 agencies are sharing information under an MoU signed April 29. If your company has foreign or nominee-type shareholders, or plans share transfers or director changes, keep source-of-funds documents and ownership records ready.