Money Laundering Reporting Officer (MLRO) & Nominated Officers Obligations

Relevant Law/ Regulation: Money Laundering Regulations 2007 (Section 20 (d)) an individual in the relevant person’s organisation is a nominated officer under Part 7 of the Proceeds of Crime Act 2002(a) and Part 3 of the Terrorism Act 2000(b)

Money Laundering Reporting Officer (MLRO) / Nominated Officer Obligations:

  • Nominated officer to be appointed, who must receive and review internal disclosures
  • Nominated officer is responsible for making external reports
  • MLRO should be able to act on their own authority
  • Adequate resources must be devoted to AML/CFT
  • MLRO is responsible for oversight of the firm’s AML systems and controls
  • Production of the Annual MLRO Report to senior management
  • Receiving reports of suspicious activity from any employee in the business
  • Considering all reports and evaluating whether there is - or seems to be - any evidence of money laundering or terrorist financing
  • Reporting any suspicious activity or transaction to the Financial Intelligence Unit, e,g. the National Crime Agency ("NCA") or equivalent by completing and submitting a Suspicious Activity Report
  • Asking the NCA for consent to continue with any transactions that they’ve reported, and making sure that no transactions are continued illegally