MLRO​

As mentioned in our article "5 Essential Points for Hiring a MLRO", the Money Laundering Reporting Officer (MRLO) was always an important role, but has gained even more significance recently. The number and size of fines for anti-money laundering (AML) and financial crime compliance (FCC) breaches is increasing, and money launderers and criminals are exploiting the coronavirus pandemic to ramp up attacks on firms.

The MLRO is a senior figure who will represent your firm. This requires the FCA's 'fit and proper person' approval: CF11 under the outgoing regime, SMF17 under SMCR. This means that a good MLRO must behave in a way that is appropriate to their position.

Purpose of the role

The main focus of the MLRO role usually is to establish and effective compliance culture within a firm for fighting against money laundering, terrorist financial, and other forms of financial crime. Because of the role's high importance, a MLRO must build strong relationships with key stakeholders, senior management and a company's board to ensure they are fully aware of all anti-money laundering matters.

​

Key Requirements

• The MLRO's knowledge must include the technical side of reporting and record-keeping requirements like Financial Conduct Authority (FCA) suspicious transaction and order reports (STORs) and National Crime Agency suspicious activity reports (SARs).

• A new MLRO needs sufficient experience to overhaul protocols and procedures to reduce the risk of breaches and avoid fines.

• They must also know how to manage a team. That includes knowing how to delegate and how to develop talented subordinates.

• Money launderers are always seeking new channels to exploit. An MLRO must not just know launderers’ latest methods, but have a keen sense of what might be a new ruse. That said, they must be pragmatic and keep a sense of proportion. They should not immediately ‘red flag’ every little thing.

​

Usual Responsibilities

• Comply at all times with the Statements and Code of Practice for Approved Persons

• Implement Anti-Money Laundering and counter-terrorist financing policies aligned with evolving regulatory obligations

• Oversee all aspects of Financial Crime related regulation, policies, procedures and controls

• Daily management of all financial crime prevention efforts. This implies providing updates, escalating issues and highlighting areas of interest to key stakeholders

• Establish and maintain appropriate risk-based monitoring processes

• Oversight of AML/KYC and CDD policies and procedures . Review client files to assess whether they are in line with regulatory requirements

• Provide support, guidance and training for team members to enhance their knowledge financial crime related matters

• Manage and mentor AML teams

• Keep up to date with statutory and regulatory developments in AML.

• Take charge of anti-money laundering training to ensure everyone in the firm receives appropriate training which meets regulatory requirements

United Kingdom

​The United Kingdom is the amalgam of Great Britain (which comprises England, Wales and Scotland) and the northern portion of Ireland. Its capital, London, is known as Europe's financial hub, and one of the world's most cosmopolitan cities. The United Kingdom is also known for other major cities, like Birmingham, Liverpool, Manchester, Belfast, Edinburgh, Glasgow and Cardiff.

The UK has made significant contributions to the world, most of them being cultural. Literature, theatre, musicals, film, television, music - many big names in these fields are from the United Kingdom.

​

Financial Services Sector in the UK

The United Kingdom - and more specifically, its capital London - has always been considered a world financial hub. Its financial services sector is quite massive: in 2018, it contributed £132 billion to the overall UK economy. It is known to be London's largest sector, with 1.1. million jobs in 2018. The city is also known for its huge amount of foreign banks: in the beginning of the 20th century, London had more foreign banks that any other city in the world.

​

Getting around

Traveling and getting around the UK is easy for anyone, thanks to its extensive and efficient public transport system, which allows you to go anywhere in the blink of an eye. Because the country is relatively small, journey times are always reasonable: for example, getting from London to Edinburgh is a 4-hour journey if you decide to take the train.

In major cities like London or Manchester, you will also find an extensive public transport system, which includes bus, tube, train, boats, and other alternatives. Getting from one point to another is extremely easy, especially if you have a traveling application like Citymapper or Google Maps on your phone to help you find the fastest - or cheapest! - journey.