London Governance & Compliance Academy

What is a Money Laundering Reporting Officer?

Money laundering is a serious crime that has been estimated to cost the UK economy in excess of £24 billion a year. As a result of the continued developments in this arena, the UK has implemented a number of regulations and practices to help combat this significant and socially damaging crime. One of the key roles in increasing the effectiveness of this fight against illegal financial activity is the Money Laundering Reporting Officer (MLRO) who is responsible for ensuring that the organisation they work for is compliant with the wide range of regulations and practices set out by the UK government. Two particular legal obligations are the focus of their work: the Proceeds of Crime Act 2002 and the Money Laundering Regulations 2017.


The MLRO takes on the responsibility for the prevention, detection and reporting of any money laundering and terrorist financing activities that cross the path of their particular organisation. They take the lead in monitoring customer transactions and reporting any suspicious activity to the National Crime Agency or other appropriate authorities. Additionally, they must be vigilant in investigating any customer complaints or queries and assessing the risk of money laundering across their business. They also need to keep up to date with changes in the law and best practice guidance, and ensure that the business meets its legal obligations. The Money Laundering Reporting Officer typically reports to the Board of Directors, and in some cases, to a company’s Money Laundering Compliance Officer (MLCO).


A typical day for an MLRO can include:


  1. Monitoring and reviewing customer accounts for suspicious activity.
  2. Conducting customer due diligence to ensure that customer profiles are up to date and accurate.
  3. Investigating any suspicious transactions or patterns of activity.
  4. Preparing reports for relevant authorities, such as the Financial Conduct Authority, to ensure compliance with anti-money laundering (AML) regulations.
  5. Liaising with other departments within the organisation to ensure that all AML processes are being followed.
  6. Keeping up to date with changes in legislation and regulations that may affect the organisation’s AML processes.
  7. Keeping records of suspicious activities and following up with customers or other financial institutions as necessary.
  8. Reporting any suspicious activity to the relevant authorities.


In order to become an MLRO, firstly it is necessary to have a good understanding of the UK’s anti-money laundering (AML) and counter-terrorist financing (CTF) regulations. This is coupled with a firm grasp of the relevant legislation, mentioned above. Above and beyond this, three particular features characterise the work of a Money Laundering Reporting Officer; qualifications, experience and training.


Firstly, the UK government has set out a number of qualifications that must be met in order to become a Money Laundering Reporting Officer. The first of these is a recognised qualification in anti-money laundering. This could be a degree in law, accounting, finance or a related field, or a professional qualification such as the Association of Governance, Risk & Compliance’s Level 3 Certificate in AML. It is also possible to have gained a qualification in AML and CTF, such as a Certificate in Anti-Money Laundering and Counter-Terrorist Financing from the Chartered Institute of Bankers. The FCA offers a full range of courses to meet these needs.


Secondly, and in addition to the qualification requirements, the UK government also requires that MLROs have a minimum of two years’ experience in a relevant field. This could include working in a financial institution, legal practice or other relevant organisation. The experience should include knowledge of the UK’s anti-money laundering regulations and practices, as well as an understanding of the risks associated with money laundering. It is also important that the MLRO understands the wider context and scope of the UK’s financial services sector, including the different types of financial products and services available. This will help the MLRO to identify and assess risks of any suspicious activity, money laundering or terrorist financing, and ensure that they can develop and implement effective policies and procedures to mitigate against these risks in the organisation they work for. This in turn ensures that the organisation is fully compliant with the regulations and practices relevant to their business.


Thirdly, it is a requirement that MLROs undertake regular training. This training should cover the UK’s anti-money laundering regulations and practices, as well as the risks associated with money laundering. It will also investigate the different types of financial products and services available, and how to identify any suspicious activity. This will involve also developing a clear picture of the different types of financial institutions and organisations that the MLRO may come into contact with. These are in a constant condition of flux and development, and so ongoing and regular training is considered to be a vital requirement in the work of any MLRO.


By meeting these requirements or qualifications, MLROs can help to ensure that the organisations they work for are fully compliant with the regulations and practices set out by the UK government and help to combat the serious crime of money laundering. Becoming an MLRO is an important role with growing prestige and importance in financial institutions.  In many instances it is also a good stepping stone to higher roles in business as it provides the opportunity to gain valuable experience in the areas of financial management, compliance and risk management. This experience may lead to a role as a compliance manager, financial controller, risk manager, or potentially even chief financial officer, for those with the interest and skills required.