5 Essential Points for Hiring a MLRO
Money Laundering Reporting Officer (MLRO) 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.
Choosing the right new MLRO is therefore crucial. To help your hiring decisions, here are five essential things an MLRO must have.
Thorough and up-to-date knowledge of AML and FCC rules.
This is a bedrock requirement, but firms occasionally skimp checking. Ensure a potential hire knows the current and incoming law and regulations in the jurisdictions they will cover.
AML and FCC evolve constantly: your MLRO must therefore be abreast of developments. A good pointer is whether they check the JMLSG website. That is the HM Treasury-approved Joint Money Laundering Steering Group, which issues AML guidance.
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).
On the subject of knowledge, check they are familiar with your firm’s AML software.
Experience of AML/ FCC work at senior level.
Your new MLRO will be heading a vital department. They must be comfortable with their responsibilities, with exercising their authority and making decisions.
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.
Can apply knowledge and experience in practice.
Some people have impressive qualifications but stumble when in real life situations. An MLRO must not. It is essential they know the practical side of the business and grasp the particular way your firm operates quickly.
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.
Much of this boils down to a prospective MLRO knowing their role is to help your business keep running by keeping it compliant and safe.
Strong interpersonal skills.
Being able to communicate and interact well with people is crucial. The MLRO needs to develop robust relationships with other parts of the business and to be seen as a useful partner, not a box-ticking hinderance.
Interpersonal skills let an MLRO ask difficult questions without enflaming potentially volatile situations. They are also required for passing on AML/FCC messages to your workforce in a way appropriate to people’s level of expertise.
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. You should be confident that they will behave in a way that is appropriate to their position.
Most importantly, the MLRO is regulators’ point of contact with your firm. They must be more than capable of dealing with the FCA and arguing your case in delicate situations.
The ‘click’ factor – but beware.
MLROs work closely with key people including chief risk and compliance officers and business unit heads. Avoid later problems by getting their input.
A hire should feel like a good ‘fit’ with your firm, but beware automatically choosing a ‘just like us’ candidate. They could well be the right person, but ask yourself some questions before making the final decision. As Ray Dalio states, references are key during a hiring process: you need to make sure you check references that go beyond dates on a resume.
Has their being ‘just like us’ meant you probed their suitability less? Have you considered a diverse talent pool? Not only is the FCA stressing the need for greater diversity in firms, looking further afield can reveal very high-quality professionals.
Finally, if SMCR’s regulatory reference requirements already apply to your firm, make sure you obtain and read one before concluding the hire.
At Rutherford, not only do we realise firms' needs differ : we also know the market and exceptional practitioners within it. Our team of consultants can support you in sorting through the 'maybes' and select the right candidates for you.
Jackson Baker is a Manager at Rutherford, the executive legal and compliance recruitment specialists.
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