Money Laundering Reporting Officers' annual reports to senior management

One of the tasks of a money laundering reporting officer (MLRO) for a FSA-Regulated firm is the production, at least annually, of a report detailing the firm's compliance with relevant legislation.

The obligation is laid out in the FSA Handbook, under the Senior Management Arrangement Systems and Controls section. Although it is the MLRO who will be producing the report to satisfy the requirements of this section (ML 7.2), it is the responsibility of the firm's senior management to "commission" the report each year; failure to do so would place the senior executives in breach of their duties, rather than the MLRO. (It remains true, however, that the responsibility to ensure the principals of a firm receive the appropriate anti-money laundering training to be aware of this fact falls to the MLRO.)

The executive is also required to consider the report, once made, and rectify any deficiencies discovered therein.

The FSA does not demand a specific structure for the report, although it does indicate that the document's findings should be broken down into the various areas of business of a Regulated firm if appropriate. Recognising that some form of template could assist MLROs with the construction of a commissioned report, the Joint Money Laundering Steering Group (JMLSG) has assembled what it calls a "suggested framework."

Although the JMLSG framework is not offered as formal guidance, its four-part structure may be considered a useful starting point. This would lead an MLRO to divide the report into sections that outline the structure of his or her firm, the systems in place within that firm, the business issues that affect it, and recommendations for future action.

The JMLSG itself recognises that the relevance of each section, and the level of detail required within those sections, will vary from industry to industry within the Regulated sector, and from firm to firm within an industry, so that the MLRO will still need to exercise judgment and expertise in drafting the commissioned report.

Ensuring Money Laundering Reporting Officer expertise with ML Solutions 4U
The role of an MLRO can be demanding, not least in that it requires knowledge of UK anti-money laundering law and its practical application in the Regulated sector. It is also to this officer that many of the potentially-onerous money laundering compliance tasks fall.

The bespoke service packages provided by ML Solutions 4U can offer the in-depth training that an MLRO can benefit from, or the wide-ranging solution applicable to an entire firm which will assist in satisfying the anti-money laundering training requirements of the Money Laundering Regulations 2007. Regulated firms may make use of our services in face-to-face sessions or through digital deliver, and can access our Helpline for dedicated advice on compliance with UK law.

For more information about how our services can support your activity as a Money Laundering Reporting Officer, please complete our enquiry form, or telephone an advisor on 0845 872 7361.

Money Laundering Information » Annual Reports from Money Laundering Reporting Officers