How it works

Staff who know or suspect money laundering report internally to the MLRO, who reviews the evidence, decides whether an external report is required, and submits it. The MLRO also oversees AML policies, training, monitoring and reporting to senior management, and is often the regulator's primary contact on financial crime matters.

Requirements by jurisdiction

• UK: Regulation 21 of the Money Laundering Regulations 2017 requires firms to appoint a nominated officer to receive internal disclosures and report to the National Crime Agency, and, where appropriate, a board-level officer responsible for MLR compliance. For FCA-regulated firms, SYSC 3.2.6I requires an MLRO with sufficient seniority, independence, resources and access to information; the role is a Senior Manager Function (SMF17) for firms within the Senior Managers and Certification Regime. Where a defence against money laundering is sought, the NCA's 7-working-day notice period applies.

• EU: The AMLR, applicable from 10 July 2027, requires obliged entities to appoint a management-level compliance manager and a compliance officer (Article 11). The compliance officer is responsible for reporting suspicious transactions to the FIU.

• US: The term MLRO is not used. Banks must designate a BSA officer responsible for coordinating and monitoring day-to-day BSA compliance (31 CFR 1020.210), with similar requirements for other financial institutions.

Common challenges

MLROs often lack sufficient resources or authority, and personal accountability under senior manager regimes raises the stakes of each decision. In smaller fintechs and crypto firms, the role can be combined with other functions, raising independence concerns.

How teams handle it in practice

Firms give the MLRO a direct reporting line to the board, documented deputies for absence cover, and management information on alert volumes, backlogs and reporting decisions. Each reporting decision is recorded with its rationale. Compliance platforms like Corsa can give MLROs a single view of escalated cases and audit trails supporting their decisions.