ECSH45791 - Who needs to be declared as a beneficial owner officer or manager (BOOM)

Beneficial Owners, Officers, and Managers (BOOMs) who must be declared on the application include:

Beneficial owners

  • Shareholders who own shares or voting rights of more than 25%
  • Owners
  • Trustees

Officers

  • Nominated officers and directors
  • Company secretaries
  • Chief executives
  • Persons controlling the company
  • Members of the management committee of a corporate body
  • An officer or governing body member of an unincorporated association and any partner
  • Secretaries or similar officers of a partnership
  • Any person acting or claiming to act in any of the above roles

Managers and senior managers

A manager or senior manager does not need to have “manager” in their job title to be considered a BOOM under MLR 2017. Any person who is responsible for either of the activities below must be included in a business’ registration.

  • Make decisions affecting compliance with MLR 2017
  • Are responsible for regulated activities

Identifying beneficial owners

When a business has multiple shareholders, it is only those who own more than 25% of the shares or voting rights that are considered beneficial owners and need to be added to the application form.

If the beneficial owner of a business is itself another business, then all the beneficial owners with shares or voting rights over 25% from that linked business also need to be added to the application. This chain of ownership continues until all the beneficial owners with shares or voting rights of more than 25% for all the linked businesses have been identified. beneficial owners from these businesses are required to be included in a business’ registration. Officers and managers of the linked business are not required to be added to the application.

Managers

Managers who are not routinely involved in the anti-money laundering and counter terrorist financing policies and procedures of the business may not need to be added to the registration as a BOOM such as a facilities manager or a human resources manager.

(This content has been withheld because of exemptions in the Freedom of Information Act 2000)