The role of the Money Laundering Reporting Officer

A Money Laundering Reporting Officer (MLRO) is the officer nominated within a firm or practice to make disclosures to the Serious Organised Crime Agency (SOCA) under the Proceeds of Crime Act 2002 and the Terrorism Act 2000.

Under Regulation 20 of the Money Laundering Regulations 2007, each firm within the regulated sector is required to appoint an MLRO, referred to as the Nominated Officer. The MLRO must:

• receive and consider internal disclosures of suspected money laundering or terrorist financing;


• decide whether there are sufficient grounds for suspicion to pass the disclosures to SOCA;


• file a Suspicious Activity Report (SAR) with SOCA where the grounds for suspicion are sufficient; and


• liaise with SOCA to deal with such matters as consent to proceed with a transaction and other disclosure issues, particularly with regards to clients or third parties.

As such, the role of the MLRO should be undertaken by a senior person within the firm who has sufficient responsibility and seniority enabling him to have access to all of the firm's client files and to make independent reporting decisions impacting on the firm's client relationships.

It is usual, but not a requirement under the Regulations, for the MLRO to take responsibility for other of the firm's anti-money laundering obligations. These might include:

• designing and setting-up internal anti-money laundering procedures and policies including customer due diligence measures, reporting, record-keeping, risk assessment, management and control systems;


• organising and arranging anti-money laundering training of the firm's staff;


• advising and guarding against tipping-off or prejudicing an investigation once an SAR has been made.

Whilst the functions of an MLRO may be delegated, this does not relieve the MLRO of his responsibility. Should the MLRO be absent or unavailable, a firm should have suitable contingency arrangements for temporary cover. Ideally a suitable deputy should be appointed for these situations.

Whilst a sole practitioner is not required to appoint a Nominated Officer, smaller firms in particular may struggle with allocating sufficient financial and time resource to ensure the anti-money laundering obligations are fully met.

ML Solutions 4U offers assistance to MLROs and their firms through a number of cost-effective, tailor made packages. These include anti-money laundering workshops and seminars, staff training, advising on office systems and procedures and the setting up of risk based compliance systems.

Should you require any further information on how we can assist the MLRO in his role, please contact us via our online enquiry form or telephone: 0845 402 0001.

Money Laundering Information » Money Laundering Reporting Officer Role