Nominated officer & MLCO

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), SI 2017/692, as amended, contains requirements for some firms to appoint a nominated officer (sometimes referred to as a money laundering reporting officer or MLRO) and a money laundering compliance officer (MLCO).

For detailed guidance, see Practice Notes: Money Laundering Regulations 2017—nominated officer—law firms and Money laundering compliance officer—law firms. See also Precedents:

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MLCO and nominated officer—combined job description and role profile—law firms
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Money Laundering Regulations 2017—nominated officer job description and role profile—law firms
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Money laundering compliance officer—MLCO—job description and role profile—law firms

Money laundering compliance officer (MLCO)

The term ‘money laundering compliance officer’ is not used in the MLR 2017. However, the term MLCO has been adopted across the profession to describe the person appointed under MLR 2017, SI 2017/692, reg 21(1)(a), ie the board-level person appointed as the officer responsible for the firm’s compliance with the MLR 2017. This is not the same as the nominated officer. See Practice Note: Money laundering compliance officer—law firms.

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