Money Laundering Reporting Officer
A Money Laundering Reporting Officer is the individual within a regulated business who is responsible for receiving internal suspicious activity reports, deciding whether to submit external SARs to the National Crime Agency, and overseeing the firm's AML compliance programme. Appointing an MLRO is a legal requirement for businesses within the scope of MLR 2017. In SRA-regulated law firms, the MLRO role sits alongside the Money Laundering Compliance Officer (MLCO) — the MLRO owns SAR reporting under POCA; the MLCO owns the firm's overall AML system under MLR 2017.
in a small accountancy practice or solicitors' firm, the MLRO is often a partner or the firm owner — and in many small law firms is the same person as the MLCO. The role must be filled formally and the holder must be sufficiently senior and competent to make judgement calls on suspicious activity.
Other terms that go with Money Laundering Reporting Officer
A Suspicious Activity Report is a formal disclosure made to the National Crime Agency (NCA) when a person in a regulated sector knows or suspects that someone is engaged in money laundering or terrorist financing. Filing a SAR provides a defence against money laundering offences. Failure to file when there is grounds to do so is itself a criminal offence.
Anti-Money Laundering refers to the laws, regulations, and procedures designed to prevent criminals from disguising illegally obtained funds as legitimate income. In the UK, the primary framework is the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017), which applies to accountants, lawyers, estate agents, and certain financial businesses.
The Money Laundering Compliance Officer is a senior individual responsible under MLR 2017 Regulation 21 for overseeing a firm's overall AML compliance programme — including the firm-wide risk assessment, policies, training, and the relationship with the supervisor. In SRA-regulated firms, the MLCO is a distinct role from the MLRO: the MLCO owns the AML *system*; the MLRO owns SAR reporting under POCA.
The Nominated Officer is the individual designated under POCA s.330(3) and s.338 to receive internal disclosures of suspicion about money laundering, and to file SARs with the NCA. In businesses subject to MLR 2017, this role is typically combined with the MLRO role into a single position — but POCA and MLR 2017 are technically separate obligations, and the legal references differ.
Put Money Laundering Reporting Officer into practice with Certivus
Knowing the term is the first step. Certivus gives you the workflows — client intake, CDD, EDD, PEP and sanctions screening, audit-ready records — to apply it across every client.
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