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MLRO - Introduction to the Role

Defines money laundering and the financing of terrorism
Identifies the statutory and regulatory origins of the Nominated Officer’s/MLRO’s responsibilities and the parallel responsibilities of senior management; understanding the ‘fit’ between the MLRO and senior management
Clarifies the origins of relevant statutes relating to AML and CTF, including the positions of the UN, the FATF and the EU; the contributions to the regime of FATF’s 49 Recommendations and the UK’s sanction’s arrangements
Explores and compares against other UK AML regulators the relevant expectations of the FSA and the FSA’s statutory objective of reducing financial crime
Determines the separation of responsibilities between the MLRO and senior management
Examines the practicalities of discharging the MLRO’s responsibilities and of having, by delegation, (some of) senior management’s responsibilities
Considers the importance of best practice standards in the industry, of relevant regulators’ guidance and, in particular, of the guidance issued by the Joint Money Laundering Steering Group (JMLSG) and other regulatory authorities for AML purposes
Explains the risk-based approach now required by statute and reflected in best practice standards, how to produce a risk based AML assessment of a firm’s business and the development therefrom of the firm’s systems, procedures and controls for AML/CTF purposes
Analyses the structural regime required to be put in place to meet and support suspicion reporting obligations within the firm and interfacing with external authorities and with special reference to the ‘consent’ regime
Recognises management information obligations in addition to the annual report required by FSA Rules to be delivered from the MLRO to senior management; and
Uses case histories and examples