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What is a Money Laundering Reporter?

Under the UK Anti-Money Laundering Regulations 2007, all businesses in the regulated financial services sector are required to appoint a Money Laundering Reporting Officer.

The agent – ​​sometimes referred to as a “designated agent” – provides oversight of the company’s anti-money laundering (AML) systems and serves as a focal point for inquiries. The role carries a significant amount of responsibility: they must have access to their company’s financial records to provide oversight and must make strategic decisions regarding activities related to money laundering and financial crime.

The agent’s duties can lead to serious legal consequences that give rise to civil and criminal prosecution. Agents bear significant personal responsibility within their company: if anti-money laundering protections are found to be insufficient, a company’s agents can face hefty fines and, in the worst cases, penalties. imprisonment for up to two years.

MLRO is an extremely important position within a company, so it is essential that senior managers understand this role and think about it carefully. Anti Money Laundering Reporting OfficerWhat does an AML Compliance Officer do?

The role of the money laundering reporting officer is defined by the Financial Conduct Authority and is described in the FCA Handbook . In addition to ensuring that their business complies with anti-money laundering controls, agents have a duty to handle any information, knowledge or suspicion of money laundering – and to properly disclose such matters to law enforcement authorities, in in this case the National Crime Agency (NCA).

From a practical perspective, officers participate in the design of relevant policies and procedures, record keeping, filing of internal and external reports, and due diligence of clients and clients. They should also participate in the ongoing review of their firm’s policies, procedures and internal professional relationships to ensure that money laundering and other financial crimes are detected and reported in accordance with the law. As such, agents may need to provide training to their colleagues within their firm.

The FCA emphasizes that a person appointed as a compliance officer should have sufficient authority to carry out their duties effectively. It is essential that AML officers inform senior management of the money laundering risk to which their business is exposed and how to manage this risk. In larger organizations, they may have to delegate some of their responsibilities or, in some cases, appoint deputy ministers to help manage their work.

Who should be an AML Compliance Officer?

It goes without saying that dedication, honesty and integrity are fundamental qualities for a money laundering reporter. Similarly, senior management must commit to providing ongoing professional support to its compliance officer.

Although there are no regulatory requirements to determine who should be appointed as a compliance officer, some important criteria should be considered when hiring for this position.


An agent should hold a position with sufficient seniority within the company – so that they can access the records and information they need to perform their anti-money laundering duties. Their position should also enable them to design, implement and enforce their company’s compliance systems and procedures.

Given the legal implications of the position and the personal responsibility they carry, your MLRO should be at least a manager-level employee, with the knowledge and experience to be able to make decisions with confidence.

Risk management

MLROs must be able to assess the risk of money laundering . This skill requires not only an understanding of criminal methods, but also an understanding of the behavior and business practices of customers and customers, who may themselves be at risk.

Risk assessment is very important to MLROs because they are responsible for calibrating their company’s anti-money laundering systems against their compliance obligations. In practice, this means avoiding the dangerous legal liabilities of under-compliance and the potentially costly burdens of over-compliance.

Legal privilege

A BMLR should have a good understanding of the concept of professional secrecy since he could be required to disclose sensitive information to the CNE, which would have legal consequences for his firm and his employees. Knowing what information must be disclosed and when is therefore a central point of the BMLR’s mandate. With this in mind, while it is not necessary for an MLRO to have a legal background, it is helpful for them to have knowledge in this area. Alternatively, an MLRO might have access to good legal advice on this aspect of their role.

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Publié initialement octobre 31, 2019, mis à jourjanvier 25, 2023

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