The Money Laundering Reporting Officer (MLRO)—duties
The Money Laundering Reporting Officer (MLRO)—duties

The following Financial Services practice note provides comprehensive and up to date legal information covering:

  • The Money Laundering Reporting Officer (MLRO)—duties
  • The roles of nominated officer and money laundering reporting officer
  • Requirement to appoint a nominated officer
  • Suspicious Activity Reports (SARs)—receipt, review and reporting by nominated officer
  • Tipping off and prejudicing an investigation
  • Failure to report by the nominated officer—the criminal offence
  • SYSC requirements relating to the MLRO
  • Approval and conduct of the MLRO
  • Other SYSC requirements relating to money laundering
  • The Financial Crime Guide on the MLRO

The roles of nominated officer and money laundering reporting officer

A nominated officer is an individual who is nominated by a firm to receive disclosures under Part 7 of the Proceeds of Crime Act 2002 (POCA 2002) or Part III of the Terrorism Act 2000 (TA 2000)—see Requirement to appoint a nominated officer below.

A money laundering reporting officer (MLRO) is an individual appointed by a firm in accordance with the Systems and Controls Sourcebook (SYSC) in the Financial Conduct Authority (FCA) Handbook to have responsibility for oversight of the firm’s compliance with the FCA's rules on systems and controls against money laundering—see SYSC requirements relating to the MLRO below.

In many firms, a single individual will be both nominated officer and MLRO, but the roles and responsibilities are different and an individual who acts as both needs to be clear as to the legal and regulatory requirements for each role.

This Practice Note therefore describes the duties of nominated officer and MLRO separately, even though in practice they may be performed by the same individual.

Requirement to appoint a nominated officer

Financial services firms to which the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692 apply are required to:

  1. appoint a nominated officer, and

  2. establish and maintain policies, controls and procedures under which (among other things) anyone in the

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