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AML Thematic Review

The Role of the Money Laundering Reporting Officer

In this thematic review we sought to understand who the money laundering reporting officer (MLRO) is and how they fulfil their responsibilities. We asked about the challenges they face, training, suspicious activity reporting, compliance monitoring and emerging risks within their client base. This review brings together these findings, provides insight and guidance from our perspective as an anti-money laundering supervisor and includes resources MLROs may find helpful.

Read the review
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About this review


240 high or high-medium risk firms took part


Includes quotes from MLROs


Highlights the regulatory expectations and requirements of the role


Incorporates key reflections from our quality assurance reviewers and AML supervision team

What is the MLRO?

The Money Laundering Regulations require every relevant organisation to appoint a nominated officer, responsible for reporting suspicion of money laundering to the NCA, and a money laundering compliance officer, responsible for the firm’s compliance with the Money Laundering Regulations. Most firms combine these two appointments into one role: the MLRO. The importance of the role cannot be stressed enough. This person(s) must ensure the firm complies with the regulations and makes the appropriate suspicious activity reports to the NCA.

A challenging role

This thematic review highlights the many day-to-day challenges for MLROs in our supervised firms, the most significant of which are the volume of work and the level of technical knowledge required to be effective. Most of our MLROs are juggling this role alongside other compliance and client-facing responsibilities. However, the review indicates they are meeting and exceeding expectations, for example we were pleased to see the effectiveness of MLROs in protecting their firms from the risk of taking on a client that could be involved in money laundering.

Throughout the report we have summarised our key reflections, setting out where we think firms and MLROs may be vulnerable to a weaker compliance framework. Firms should use this information to reflect on the effectiveness of their firm's procedures and the MLRO.

A good MLRO needs to be someone who is approachable, sceptical, a good auditor, prepared to challenge suspicious activity, a good communicator and a good delegator.

ICAEW Quality Assurance Reviewer