MLRO - Money Laundering Reporting Officer
The named individual responsible for the AML programme of an obligated entity - receiver of internal disclosures, signer of SARs, and the regulator's first port of call.
Definition
The Money Laundering Reporting Officer (MLRO) - known in some jurisdictions as the Nominated Officer or BSA Officer - is the named individual responsible for the day-to-day operation of an obligated entity's AML/CFT programme. The MLRO receives internal suspicion disclosures, decides whether to file external SARs, and is the primary point of contact for the FIU and supervisor.
Core duties
- Receive and assess internal suspicion reports.
- File external SARs / STRs to the FIU when warranted.
- Maintain the AML risk assessment and policies.
- Oversee training, monitoring effectiveness and remediation.
- Report periodically to the management body / board.
Regulatory anchor
AMLD4 Article 8(4) and Article 46 in the EU; FCA SYSC 6.3 in the UK; FinCEN BSA officer requirements in the US; the upcoming AMLR formalises a "compliance manager" role at management-body level alongside the operational MLRO.