Money Laundering Regulations 2017—nominated officer—law firms

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

  • Money Laundering Regulations 2017—nominated officer—law firms
  • What is a nominated officer?
  • Do you have to appoint a nominated officer?
  • Compulsory appointment of nominated officer
  • Voluntary appointment of nominated officer
  • Special position of sole practitioners
  • Special position of FCA-authorised firms
  • Qualification requirements
  • Registration of nominated officer
  • Nominated officer's core duties
  • More...

Money Laundering Regulations 2017—nominated officer—law firms

This document reflects draft Legal Sector Affinity Group (LSAG) AML guidance, published on 20 January 2021. It awaits HM Treasury approval. Note that any content may be amended before the final version is published with the Treasury's approval.

This Practice Note sets out when firms must appoint a nominated officer, the duties of the nominated officer and practical steps nominated officers can take to fulfil their role. It reflects the requirements of the MLR 2017, as amended.

What is a nominated officer?

The nominated officer is the person nominated to receive and consider suspicious activity reports (SARs). They are also expected to make external SARs to the National Crime Agency (NCA). The nominated officer is sometimes referred to as a Money Laundering Reporting Officer or MLRO.

The nominated officer is not the same as the money laundering compliance officer (MLCO), ie the board-level person appointed as the officer responsible for the firm’s compliance with MLR 2017—see below: Relationship between the nominated officer and MLCO.

Do you have to appoint a nominated officer?

Not all firms have to appoint nominated officer.

Compulsory appointment of nominated officer

You must appoint a nominated officer if the MLR 2017 apply to your business, ie you are:

  1. a relevant person

  2. acting in the course of business in the UK

  3. not subject to one of the very narrowly drawn exclusions in Regulation

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