What keeps MLROs awake at night?
The risks for MLROs are high. If authorities can prove that preventions for money laundering were not sufficient then it could lead to imprisonment.
Each firm within the UK regulated financial services sector is required to appoint a Money Laundering Reporting Officer (MLRO) who is the focal point for a firm’s adherence to anti-money laundering and terrorist financing regulations, reporting to a director or senior manager.
An MLRO must also consider internal disclosures of suspected money laundering or terrorist financing, decide whether there are sufficient grounds for suspicion to pass disclosures to the National Crime Agency (NCA), file suspicious activity reports (SARs) with the NCA and liaise with the NCA to deal with such matters as “consent to proceed with a transaction” and other disclosure issues.