Should a MLRO / License member be DBS checked ?

Should a MLRC/Lecensed practicing member be DBS checked, as required by The Money Laundering regu 17

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Should a MLRO / Lecensed practicing member be DBS checked, as required by The Money Laundering Reglation 2017 ?

If yes, under what section of the regulation please ? 

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David Winch
By David Winch
08th Jun 2018 13:32

Reg 26 refers.
David

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Replying to davidwinch:
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By WESTA
08th Jun 2018 15:19

Many thanks David

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By WESTA
08th Jun 2018 13:45

Before 26/06/18

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By Mr_awol
08th Jun 2018 16:38

So the answer is no - but the institute (or other regulatory body) can request one if they choose?

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Replying to Mr_awol:
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By WESTA
11th Jun 2018 09:54

Precisely !

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Replying to WESTA:
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By Mr_awol
11th Jun 2018 10:12

As long as I can merrily ignore it (and assume that ICAEW either did or didn't undertake one for me, however they saw fit) then I'm happy!

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Replying to Mr_awol:
David Winch
By David Winch
11th Jun 2018 10:37

Per ICAEW,
"All supervised firms must take reasonable care to ensure no-one is appointed, or continues to act, as a BOOM (beneficial owner, officer or manager) after 26 June 2018 without approval. Regulation 26 does not oblige supervised firms to carry out criminal record checks on all BOOMs, however firms should carefully consider what steps they need to take to gain the necessary assurance that all of their BOOMs do not have any relevant criminal convictions.

Our strong recommendation is that compliance with Regulation 26 is evidenced by getting basic criminal record checks for all BOOMs prior to 26 June 2018 and for firms in higher risk categories, this is a requirement."

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By nigelrmorris
11th Jun 2018 12:08

So are we saying that to meet these requirements the ICAEW are stating that they would strongly recommend a sole practitioner needs to undertake a DBS check on "himself" (only used for ease, could be "herself") to confirm to himself that he has no criminal record ? .....

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Replying to nigelrmorris:
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By paulwakefield1
11th Jun 2018 12:51

Yes. I had this conversation with ICAEW last week.

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