The supervision requirement also applies to all beneficial owners, officers and managers (BOOMs). While AAT will not request evidence of their certificates, we encourage you to ensure that any of your colleagues that fall into these categories understand their obligations.

The examples below will help you understand if you have any BOOMs in your firm.

Beneficial owner

Beneficial owners include:

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


Those defined as officers would 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
  • a member of the firm’s management board or equivalent.


Managers include:

  • the nominated officer (the MLRO)
  • the member of the board of directors (or if there is no board, its equivalent management body) or of its senior management as the officer responsible for the relevant person’s compliance with MLR17)
  • 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 AML policies and procedures, in relation to:
    • 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
    • AML record keeping.

Read more about BOOMs on AAT Comment 

Source: AAT News

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