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Anti-money laundering

Criminal record checks on BOOMs

This page is part of a series on the 10 most common issues we've found when reviewing firms' compliance with the Anti-money Laundering Regulations.
See the 10 most common issues
A common AML compliance issue is when firms haven’t obtained criminal record certificates for key staff.

What is a BOOM?

A BOOM is specifically defined as a beneficial owner, officer, or manager.

What do the regulations say?

Since 26 June 2018, all our supervised firms must take reasonable care to ensure no-one is appointed, or continues to act, as a BOOM without ICAEW’s approval. ICAEW can only approve a BOOM if that individual has no relevant unspent criminal convictions and so, to prove that we can approve a BOOM, we require all BOOMs to obtain criminal record checks.

What we found in our 2021/22 AML compliance reviews

We found that some firms hadn't yet obtained criminal record certificates for the BOOMs in the firm. We review these checks during onsite monitoring visits, or we may write to the firm and ask it to send the certificates to us.

Resources to support compliance

Read the report

Read our 2021/22 anti-money laundering supervision report for more detail on the results of our monitoring reviews, the outcomes of those reviews and enforcement action taken. The report also summarises all of our anti-money laundering supervisory activity during the period.