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Definition of a beneficial owner, officer or manager (BOOM)

Under Regulation 26 of MLR17, from 26 June 2018, ICAEW must approve all beneficial owners, officers and managers (BOOMs) in our supervised firms. The MLR17 define these terms but the Accountancy Affinity Group (which comprises all the accountancy professional body supervisors) have agreed further guidance to identify the relevant roles:

Officer

This should include:

  • a sole practitioner;
  • a partner in a partnership (including a Scottish Limited Partnership (SLP));
  • a member in a limited liability partnership (LLP);
  • a director or company secretary in a limited company; and
  • a member of the firm’s management board or equivalent.

Beneficial owner

This should include:

  • a sole practitioner;
  • a partner, or LLP member, in a firm who:
    • holds (directly or indirectly) more than 25% of the capital, or profits or voting rights; or
    • exercises ultimate control; and
  • a shareholder in a limited company who:
    • holds (directly or indirectly) more than 25% of the shares or voting rights; or
    • ultimately owns, or exercises ultimate control.

Manager

This should include:

  • the nominated officer (the MLRO);
  • the member of the board of directors (or if there is no board, of its equivalent management body) or of its senior management as the officer responsible for the firm’s compliance with MLR17; and
  • any other principal, senior manager, or member of a management committee who is responsible for setting, approving or ensuring the firm’s compliance with the firm’s Anti-Money Laundering policies and procedures, in relation to the following areas:
    • client acceptance procedures;
    • the firm’s risk management practices;
    • internal controls, including employee screening and training for AML purposes;
    • internal audit or the annual AML compliance review process;
    • customer due diligence, including policies for reliance; and
    • AML record keeping.