MLRO Queue

The daily-driver inbox for the MLRO. Whenever you sit down to do MLRO work, this is where you start.

What it shows

A live list of items needing the MLRO's attention, grouped by urgency:

HIGH

• AML hits awaiting MLRO disposition: every PEP / sanctions / adverse-media hit needs a decision, and then the screening needs a sign-off. The item stays here until the screening is signed off, and the client cannot be approved before then. See Reviewing possible AML matches.
• Internal SARs awaiting MLRO review: staff who suspect money laundering must report it internally under POCA s.330. Your job is to review and either dismiss with reasoning or escalate to an external SAR to the NCA.
• Draft external SARs > 3 days old: once a SAR is drafted but not submitted, the clock starts. POCA timelines mean you can't sit on these.

MEDIUM

• Open material-change flags: something about the client changed and their risk view needs a fresh look. Certivus raises these on its own when:

  • an AML hit is confirmed or escalated
  • a monitoring alert is resolved as a real match, or escalated to you
  • a new service is added for a client who already has a risk assessment
  • a beneficial owner is added or removed, or their ownership or control changes
  • the people with significant control change at Companies House (seen when the company's officers are refreshed)
  • a client presents a different identity document, or their identity document expires
  • source of funds or wealth evidence is recorded as inadequate, or the client declines to provide it
  • you are asked to review the client ("MLRO review requested")

  Each kind of change opens one flag per client: a second change of the same kind while the flag is open does not add another. Anyone who is an owner, a manager or the firm's MLRO can also flag a client by hand: open the client, then More actions → Flag for review, and give a reason. The flag stays open until someone re-scores the client's risk or marks it resolved with a note. Some clients were approved before the current approval checks existed and are missing a risk assessment or an AML screening sign-off. They carry a flag that says what is missing. Their approval has not been changed: complete what is missing, or record why no further action is needed, then mark the flag resolved on the client page.

• Client flagged for reassessment: one row per client with an open flag, dated from when it was raised.

• Periodic risk review due: the client's scheduled review date has passed. This is the regular review every client gets on a cycle set by their risk rating, separate from the flags above.

Deleted and archived clients, and clients whose business relationship has ended, do not appear.

LOW

• PCP review overdue: your published PCP has passed its review cadence date.
• Audit review overdue: no independent review in the last 12 months. MLR 2017 reg 21(1)(c) requires regular reviews by someone independent of your AML function; a review by your own MLRO does not count. Only a sole practitioner with no relevant employees is exempt.

How to work it

Oldest first within each urgency band. Click any row to deep-link to the page where you can action it. The queue refreshes on tab focus, so it shrinks as you work through it.

What it doesn't show

• Scheduled items not yet due: use the AML Calendar for the forward view.
• State transitions that have already happened: use the Audit Log for the history.

When the queue is empty

Genuinely good news. New AML hits, internal SARs, material flags, and overdue reassessments will appear here automatically. Nothing requires MLRO action right now.