ABSTRACT

The requirements for the production of what is generally referred to as the money laundering reporting officer’s (MLRO) Report are laid down in the Financial Services Authority (FSA) Rules. This report is considered to be a fundamental part of a firm’s compliance monitoring. The report obviously must cover all aspects and any problems or deficiencies in Customer Due Diligence, monitoring procedures and the reporting to Serious Organised Crime Agency including statistics, record-keeping and staff training. A careful examination of this report will enable senior management to ascertain what actions need to be taken and where. If the MLRO report highlights significant failings or shortcomings, senior management must devise and implement a process of correction. In December 2006, after discussions with the FSA, the Joint Money Laundering Steering Group produced a template suggesting a suitable presentation and content framework for working paper underpinning the production of the MLRO Annual Report.