Nominated Officer
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. However, POCA and MLR 2017 are technically separate obligations, and the legal references differ.
most UK accountancy practices appoint a single individual who is both the MLRO (MLR 2017 oversight role) and the Nominated Officer (POCA reporting role). Either title is acceptable; the legal responsibilities cover both. The role must be filled, in writing, by a sufficiently senior person.
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All tutorialsWhat the MLRO role actually involves
What lands in the queue, how to work it, and what a supervisor looks at afterwards.
How different roles use Nominated Officer
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Partner or director
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ContinueMLRO or compliance lead
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ContinueClient-facing team member
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ContinueOther terms that go with Nominated 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.
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.
Before you treat Nominated Officer as handled
- Confirm which regulation, policy, or internal procedure the term maps to.
- Document the decision or evidence trail in the client file, not only in email or chat.
- Escalate where the term indicates higher risk, sanctions exposure, PEP status, suspicion, or missing evidence.
- Keep the wording consistent across onboarding, review notes, training material, and inspection packs.
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