The Money Laundering Reporting Officer (MLRO) will operate under delegated authority from the Board and have overall responsibility for the establishment and maintenance of effective anti-money laundering (AML) and counter-terrorist financing (CTF) systems and controls. The MLRO will be formally appointed by the Board, be a member of senior management and will report directly to the Board. The MLRO will be based at the UK Head Office.
Establishing AML and CTF systems and controls
- Maintaining and developing the risk based approach to AML and CTF arrangements - carrying out regular assessments of the adequacy of systems and controls to ensure that risks are managed effectively.
- Overseeing the implementation of appropriate AML and CTF policies and procedures, including the operation of the risk-based approach.
- Determining the level of resources required to execute appropriate AML and CTF policies and procedures.
- Reviewing the output from the suspicious activity monitoring processes.
- Ensuring that AML and CTF requirements are considered as part of the development of new products, or service changes.
- Obtaining board approval for significant process changes.
- Ensure that policies and procedures are accurately documented in the AML Manual which should be available to staff and used to guide training.
- Ensure that the Board are kept informed of the money laundering risks posed by the business and its activities, and how these are managed and mitigated.
- Reporting to the Board on a regular basis detailing the operation and effectiveness of the systems and controls used to combat financial crime.
- Documenting and ensuring that any actions recommended by the Board are implemented.
- Arrange and assist with regulatory visits and audit inspections.
Maintaining relevance of the AML systems
- Regularly reviewing developments in applicable legislation and guidance (domestic and international where the business is involved).
- Ensuring that policies are updated to meet changing regulatory and business requirements.
- Ensuring that the operation of systems and controls are monitored and that they implement policy.
- Maintaining up to date AML documentation.
- Ensuring that relevant staff are provided with AML and CTF training appropriate for their position (frequency and content) and that all new staff receive training within the specified period. Ensure that training materials remain up-to-date and relevant to the business.
Reporting suspicious activity
- Maintain an internal reporting process for receiving internal Suspicious Activity Reports (SARs).
- Investigating internal SARs, using all available resources.
- Deciding, following investigation, whether the internal report gives rise to knowledge or suspicion or reasonable grounds for knowledge or suspicion and submitting an external SAR to the National Crime Agency (NCA) where appropriate.
- Documenting the reasons for not submitting an external SAR to the NCA where an internal report has been made, considered and deemed not to be suspicious.
- Ensure that relevant records are retained for the prescribed periods.
- Where required be the main point of contact for law enforcement officials.
Qualifications and experience
The emphasis of this position is on developing, operating and maintaining systems and controls to prevent the firm’s products and services being used for the purposes of financial crime and to meet reporting requirements.
Minimum 3 years of experience in financial and/or compliance related business functions. Experience in developing and administering internal controls and processes. Ability to work collaboratively with a broad range of business functions, with an emphasis on senior management, is essential. A demonstrated ability to work with diverse groups of people is required. A willingness to take personal legal responsibility for the prevention of financial crime is essential.
A professional compliance, or financial qualification, and membership of a recognised professional body, would be advantageous but not a pre-requisite.