Money laundering compliance officer

The following Risk & Compliance practice note provides comprehensive and up to date legal information covering:

  • Money laundering compliance officer
  • What is an MLCO?
  • Is it compulsory to appoint an MLCO?
  • Qualifying requirements—who to appoint
  • Responsibilities of the MLCO
  • Relationship between MLCO, nominated officer
  • Senior management responsibilities
  • Registration of MLCO
  • Training the MLCO
  • Oversight of organisation’s compliance arrangements
  • More...

Money laundering compliance officer

This Practice Note is intended for commercial organisations that are subject to the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692. It provides guidance on the requirement to appoint a board-level (or equivalent) person as the officer responsible for the organisation’s compliance with MLR 2017. This position is commonly known as the money laundering compliance officer (MLCO) or board-level person.

This Practice Note reflects the requirements of the MLR 2017 and includes suggested good practice. However, you will need to consider whether your organisation’s AML supervisory authority imposes any additional requirements or restrictions. Law firms regulated by the SRA should refer to Practice Note: Money laundering compliance officer—law firms.

Not all organisations are required to appoint an MLCO. Sole traders are not required to do so and other organisations are only required to appoint an MLCO where:

  1. they are caught by MLR 2017, and

  2. it is appropriate to appoint an individual having regard to the size and nature of the business

See below: Is it compulsory to appoint an MLCO?

What is an MLCO?

The term ‘money laundering compliance officer’ is not used in MLR 2017.

However, the term MLCO has been adopted in various sectors to describe the person appointed under reg 21(1)(a), ie the board-level person appointed as the officer responsible for the organisation’s

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