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Roles and Responsibilities of the Money Laundering Reporting Officer (MLRO)

Understand fully the roles and responsibilities of the MLRO

Money Laundering Reporting Officer Training Course

A one-day course

Video Overview

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  • We have delivered FCC and MLRO training programs to many leading organizations including the world’s largest trade finance bank where the outsourced training program is entering its 7th year and Redcliffe remains the main provider of trainers in both the UK and overseas. We have also delivered extensive MLRO training to small and medium-sized firms
  • Based on this Global Bank training program and our considerable experience of training small and medium-sized firms, we are certain we have as much and probably more experience delivering quality cutting edge FCC & MLRO training as anyone in the marketplace
  • We believe this is one of the most up to date on-the-spot courses on offer
  • Our trainers are all successful and very senior retired executives who are well aware of how important the MLRO is to the successful control of FCC
  • We have developed highly interactive and very enjoyable case studies to enhance the learning points. All delegates report that these are a high point.
  • We are always judged by our results which speak for themselves and the feedback received from previous delegates has always been excellent.

  • Explain the critical role of the MLRO function in establishing, implementing and monitoring an effective anti-money laundering and CTF policy
  • Explain the purpose and function of the risk-based approach
  • Identify the key responsibilities of the MLRO and his or her team
  • Demonstrate with examples, both good and bad AML practice
  • Ensure delegates understand the importance of the MLRO function in relation to statutory requirements
  • Consider the implications of MLR2017, 2019 & 6th MLD
  • Consider PSC requirements & Trust registration
  • Consider PEP criteria and the single European Register
  • Explain how the MLRO must oversee and control the AML process and how this is documented
  • Appreciate the need for regular and documented staff training
  • Understand the importance of an effective escalation process including SAR/STR’s and the need for an effective Whistleblowing process
  • Appreciate the importance of the Annual(or more frequent) MLRO report
  • Appreciate how it all works in practice and where the pinch points often occur

The Role of the MLRO - Overview:

  • A critically important role with the responsibility of ensuring FCC measures are effective
  • Responsible for implementing and overseeing the CDD process, onboarding, transactions  monitoring and alert escalation
  • Ensuring new and changing regulatory requirements are complied with fully and in a timely fashion
  • Developing internal and external reporting processes
  • Keeping records
  • Establishing, maintaining and overseeing internal controls
  • The AML/CTF risk assessment
  • The essential requirement to ensure proper training of staff
  • Communication of AML/CTF policy and issues within the business
  • Case Study/Example

The Initial Risk Assessment and Identifying and Evaluating Key Risks

  • Country risk Assessment
  • Institution’s risk assessment
  • Adopting the Risk-Based Approach
  • How the MLRO, Compliance Officer, Chief Risk Officer, Internal Audit and the Board should co-ordinate
  • What makes an effective Compliance Officer?
  • Accountability of the Compliance Officer
  • Interdependencies with other control functions
  • Primary, secondary and on-demand compliance
  • The Compliance Officer’s Activities – and the support required
  • Case Study/Example

Internal Systems & Policies Including Implementing an Effective Compliance Framework and a Monitoring Programme

  • Analysing legal and regulatory rules
  • Identifying risks
  • Creating an internal AML/CTF Policy
  • Designing control and procedures
  • Generating management information
  • Creating an effective compliance culture
  • Monitoring
  • Case Study/Example

Compliance and Corporate Governance

  • How does the MLRO contribute to Corporate Governance and help manage risk
  • Reporting to the Board and Board oversight
  • Creating an effective reporting/escalation process
  • Working with all levels of management to ensure the training provided is suitable for the business on a risk-based basis
  • Dealing with Regulators
  • Dealing with the NCA
  • Submitting regular (minimum annual) MLRO reports to the Board
  • Case Study/Example

Keeping up with “The Rules” and the ever-changing risks surrounding Compliance and Financial Crime Prevention

  • FINCEN revelations. A real issue or selective reporting?
  • MLR 2017 & 2019
  • The 6th Money Laundering Directives
  • PSC requirements & Trust registration
  • PEP criteria and the single European Register
  • Other key/current issues in
    • Compliance
    • AML & CTF
    • Fraud, Identity Theft & Cybercrime
  • Case Study/Example

Managing the Risk of Money Laundering

  • Offshore Issues, PEPs, and EPs
  • Know Your Client (KYC) and Identification & Verification (ID&V)
  • Annual and other regular reviews
  • High-risk clients
  • Monitoring systems
  • Testing procedures
  • Case Study/Example

Evaluation of Internal Reports

  • Disclosure & Escalation
  • Whistleblowing process
  • Requesting Consent – where applicable
  • Reminding staff about tipping off
  • Escalating to the NCA
  • Obtaining further information
  • Identifying the reasons for suspicion
  • Documenting decisions not to report externally
  • Submitting/Escalating SAR’s
  • Policing the process
  • Reporting past practices which recent reports indicate could now be money laundering
  • Policing the notice period following a SAR
  • Policing moratorium periods imposed by the NCA
  • Case Study/Example

Other Regulatory Risks

  • Information Security and Data Protection
  • Market Abuse and Insider Dealing
  • Bribery and Corruption
  • Sanctions
  • …and other types and Risks in on-shore and off-shore Banking
  • Case Study/Example

Accounting for People Risks in Risk Management

  • Understanding the importance of human error in procedures-driven environments
  • Common human factor problems
  • Steep authority gradients
  • Reliance vacuums
  • Dominant individuals
  • Identifying and addressing human factor issues
  • Developing an effective compliance culture
  • Case Study/Example

Potential Criminal Abuse of Private Banking Services, Trusts, and Corporate Services companies

  • Offshore companies and corporate services analysed
  • Offshore trusts and trustee services analysed
  • The criticality of fiduciary duty
  • Understanding commercial rationale
  • AML trust and company vulnerabilities
  • Examples of abuse

Course Conclusion – Open Forum and Wrap Up

The trainer had a highly successful, long and varied “fast track” career in Lloyds Bank which led him to a very senior management position in the bank’s private banking and wealth management division at an early age. He was then “headhunted” to join a merchant bank to head the risk function at main board director level. He now has over 40 years of experience in the UK banking and financial services sector.

The trainer has been a freelance Compliance, FCC & AML training consultant since retiring and is currently an external Master Trainer at both HSBC and Bank of China. At HSBC he has been a leading member of their global FCC & AML training programme which is now entering its sixth year. He has created and delivered training to a vast range of clients, from global giants to small firms and partnerships. He is an accomplished global trainer and has delivered extensive programmes in the UK, USA, South America, Europe, Africa, Asia and the Middle East.

He is a highly adaptive, hands-on and highly sought-after facilitator who always receives excellent feedback from delegates. He is comfortable training at any level of seniority and experience, from “black belts” to novices. As well as his Compliance, FCC & AML specialism, his expertise includes but is not limited to Risk Management, Trade Finance and all major aspects of Corporate, Private & Retail Banking. He is also a highly experienced soft skills trainer and has completed numerous “train the trainer” assignments.

As far as the creation of AML & FCC policies is concerned, the gatekeeper, controller and where the buck clearly stops, is the MLRO.  This is a critically important position within any financial services firm. When it comes to the identification, detection, escalation, reporting, managing and training of staff on Anti Money Laundering procedures it is the personal responsibility of the MLRO to ensure this all happens as effectively and efficiently as possible. In most jurisdictions, it is a mandatory role.

The MLRO should be a senior manager within the business and have the power to drive policy decisions and actions. He/she should have undergone a sufficient level of training experience and hold suitable qualifications.

This highly interactive one day workshop is designed to explain fully the roles and responsibilities of an MLRO. It includes a number of interesting case studies based on real-life examples which will be used to enhance the learning experience. Delegate participation will be strongly encouraged and many attendees tell us that the ability to swap “war stories” and compare notes is a very helpful feature. Whether you are the MLRO or part of the team, we can help you understand your role and to discharge your duties more effectively.

Who Should Attend:

MLRO’s and all staff working within a compliance function especially those charged with AML escalations/investigations. Members of the internal audit function. Senior managers and top management would also derive considerable benefit from attending as they are the ultimate risk owners.

  • The trainer was very knowledgeable and tried to keep everybody engaged by relating examples to peoples job roles.
  • The tutor was very good and he interacted with us well, gave us a chance to get involved properly by asking relevant knowledge questions and made us laugh too!
  • It was refreshing, friendly, explained in a lively and interesting way, entertaining and without using excessive jargon. The structure was clear and organised. Good timing and calculated breaks. All in all, a course which seemed "effortless", but probably needed quite some effort to prepare.
  • Knowledge gained will help perform the role of MLRO.

Have this course presented In-House

  • On a date, time and in a location of your choice
  • Topics expanded or deleted to your bespoke requirements
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Have this course pre-recorded

  • Full course recording edited exclusively for your company
  • Files converted to enable housing on your LMS
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