Beneficial Owners, Officers or Managers & Nominated Officers
IPA Insolvency Practitioner newsletter AML Digest, August 2024
Beneficial owners, officers or managers of a firm, or a sole practitioner, are known as BOOMs and Reg 26 MLR17 advises that no person can be a BOOM unless they are approved by the supervisory authority for the relevant firm.
As you may recall, details of BOOMs are now requested at part of the information required for licence renewal, and the IPA will start to carry out a dip sample of BOOM information to check that the details provided marry with our records and that proper authorisation has been requested and provided.
It is important to ensure that where you appoint a new BOOM that you advise the IPA (or whomever your AML supervisory authority is of the new BOOM) and provide them with any documentation they require to provide approval. For the IPA this would be a current DBS check (or equivalent).
Where you move firm, or set up a new firm, please ensure that as well as advising the IPA of your new contact details, that you advise of the relevant BOOMs so that these can be confirmed as approved – and where necessary – appropriate action taken to ensure approval can be provided.
Please also remember that changes to a firm’s Nominated Officer are required to be advised to your AML supervisory authority within 14 days of their appointment as per Reg 21 (3) & (4)(b).