Who needs to complete a declaration?
The form has been designed as a declaration for completion by both principals and members of staff. Principals and staff involved in work that requires Registered Auditor status should complete such a declaration annually, but best practice may be to require all personnel to comply.
It is the firm’s responsibility to ensure that the approval of beneficial owners, officers and managers (BOOMs) remains valid in accordance with regulation 26 of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017.
Dealing with the responses received
Some of the statements within the declaration are fundamental and identification of an issue, for example certain fit and proper situations and confidentiality breaches, may represent issues that constitute gross misconduct and result in dismissal and/or legal action. To protect itself, a firm should normally bring such matters to the attention of personnel in a contract of employment but, given the complexity of this area, it is strongly recommended that legal advice is taken before introducing change.