Handbook of Anti-Money Laundering.

CHAPTER 12THE ROLE OF THE MONEY LAUNDERING REPORTING OFFICER

12.1 WHAT IS A MONEY LAUNDERING REPORTING OFFICER?

International organisations such as the Financial Action Task Force and the Bank for International Settlements actually do not have the ability to impose rules or regulations. Instead, this is left to the local jurisdiction to implement according to the requirements of the local legal and regulatory framework. Consequently, global money-laundering regulations place the requirement to instigate local rules and regulations that set out responsibilities, accountabilities and procedures on individual countries.

In order to comply with what are often referred to as the systems and control function requirements regarding money-laundering deterrence, there is normally a requirement to appoint a responsible individual to take ownership of the process, who is referred to as a Money Laundering Reporting Officer (or MLRO). In the few jurisdictions where there is no specific requirement for a Money Laundering Reporting Officer to be appointed, there is still a requirement for an individual to take similar responsibilities.

Among the key responsibilities is the requirement that the MLRO should be the first point of contact within a firm for any issues which relate directly or indirectly to money-laundering deterrence or suspected terrorist-financing activity. They should be responsible for any strategic decisions made by the firm concerning money laundering and financial crime ...