ABSTRACT

The position of the Money Laundering Reporting Officer (MLRO) is fundamental to many aspects of meeting the anti-money laundering requirements. The law requires the appointment of a ‘nominated person’ to carry out various functions including the receiving of internal suspicion reports. This job, known as the MLRO, became the standard description of the job in many countries. It is clear that the Financial Services Authority considers the MLRO to be the focal point within all regulated firms in respect of all aspects of anti-money laundering policies and procedures. From this it can be seen that the MLRO is a specialist job and it is one of the most important positions in any firm within the regulated sector. To achieve all that is required of them, an MLRO in a regulated firm must be a member of senior management and be able to operate both independently and autonomously.