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, 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.
Officer includes:
- 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.
Manager includes:
- the nominated officer (MLRO);
- the Money Laundering Compliance Principal (i.e.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 relevant person’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.