Money Laundering Regulations 2017—governance and reporting lines

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

  • Money Laundering Regulations 2017—governance and reporting lines
  • Who are the organisation's managers?
  • Money laundering compliance officer
  • Is it compulsory to appoint an MLCO
  • Responsibilities of the MLCO
  • Nominated officer
  • Relationship between MLCO and nominated officer
  • What should senior management be doing in relation to AML?
  • Evidence of senior management involvement

Money Laundering Regulations 2017—governance and reporting lines

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692 set out various requirements for the assessment and management of money laundering and terrorist financing risks to which your organisation's business is subject. The management of money laundering risks often falls to the nominated officer and, robust governance and strong reporting lines are needed to assist the organisation and its nominated officer to discharge their responsibilities.

This Practice Note sets out some of the key considerations for establishing appropriate governance structures and reporting lines as part of the management of the risks of money laundering and terrorist financing to which your organisation may be subject. It has been updated to reflect the requirements of the MLR 2017, as amended.

It provides guidance which is of general application. You should check whether the MLR 2017 contain additional or varied requirements for your sector and whether your regulatory body has any additional, sector specific requirements in relation to governance and reporting lines.

Who are the organisation's managers?

While anti-money laundering (AML) and counter-terrorist financing (CTF) compliance is a matter for all, relevant 'on the ground' managers are likely to include the nominated officer and any money laundering compliance officer (MLCO). They will be supported by or report to the board, senior management committee or similar,

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