The Money Laundering Reporting Officer (MLRO) is the individual in a UK regulated firm responsible for receiving internal suspicion reports from staff, deciding whether to submit a Suspicious Activity Report (SAR) to the National Crime Agency (NCA), and overseeing the firm’s anti-money laundering framework. Every firm subject to the Money Laundering Regulations 2017 must appoint a nominated officer to carry out this function. Under the Senior Managers and Certification Regime (SM&CR), the MLRO holds Senior Management Function 17 (SMF17) and carries personal regulatory accountability.
Why the MLRO matters
The MLRO is the firm’s primary point of accountability for AML compliance. If a suspicious transaction is not reported, or is reported incorrectly, the MLRO can face personal liability. The FCA expects the MLRO to have sufficient seniority, experience and resources to carry out the role effectively, and to be free to escalate concerns without obstruction.
The role sits at the intersection of two regimes. The Money Laundering Regulations 2017 require the appointment of a nominated officer to receive internal disclosures; SM&CR attaches that responsibility to a named senior individual through SMF17, making the obligation personal rather than purely organisational.
Who it applies to
Any individual appointed as nominated officer or MLRO at a firm within scope of the MLR 2017, typically a senior compliance professional. Smaller firms may combine the MLRO role with other compliance responsibilities, but the function itself cannot be left unfilled.
Related terms
SAR, CDD, EDD, tipping off and SM&CR.