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

2 Part Course | Learn the roles and responsibilities of the MLRO

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A one-day MLRO course presented over two-half days in a virtual class from 9:30am to 1:00pm UK time

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Download: Course Category Brochure | Course Outline

Part One

Session 1: 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
MLRO Training Case Study/Example

Session 2: The Initial Money Laundering 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 coordinate
What makes an effective MLRO 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

Session 3: 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

Session 4: 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

Session 5: 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 (4^th & 5^th Money Laundering directives enshrined in Law)
The 6^thMoney 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

Part Two

Session 1: 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
MLRO Training Case Study/Example

Session 2: 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 SARs
Policing the process
Reporting past AML 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

Session 3: 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

Session 4: Accounting for People Risks in Anti-Money Laundering 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

Session 5: 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

MLRO Course Conclusion – Open Forum and Wrap-Up

Redcliffe's MLRO workshop is led by an expert with an extensive and distinguished career in the banking and financial services industry. Beginning with a fast-tracked trajectory at Lloyds Bank, he rapidly ascended to a senior management role within the private banking and wealth management division. His expertise was soon recognised, leading to a headhunting opportunity at a merchant bank where he served as Head of Risk at the main board director level. With over 40 years of experience in the UK financial sector, he brings a wealth of knowledge to every training session.

Since retiring, our trainer has established himself as a prominent freelance consultant specialising in Compliance, Financial Crime Compliance (FCC), and Anti-Money Laundering (AML) training. He currently serves as an external Master Trainer for HSBC and Bank of China, playing a pivotal role in HSBC’s global FCC & AML training program, which is now in its eighth year. His training portfolio is extensive; having designed and delivered money laundering reporting officer training to a broad range of clients, from global corporations to boutique firms. His international experience spans the UK, USA, South America, Europe, Africa, Asia, and the Middle East.

Renowned for his adaptability and hands-on approach, he consistently earns outstanding feedback from participants. He is adept at engaging with professionals across all levels of seniority and expertise, from seasoned experts to those new to the field. In addition to his specialisations in the MLRO, Compliance, FCC, and AML, his areas of expertise include Risk Management, Trade Finance, and all facets of Corporate, Private, and Retail Banking. Moreover, he is a highly skilled soft skills trainer with a track record of success in “train the trainer” programs.

This MLRO training course will teach you the following:

The critical role of the MLRO function in establishing, implementing and monitoring an effective anti-money laundering and CTF policy.
The purpose and function of the risk-based approach.
The key responsibilities of the MLRO and his or her team.
Demonstrate with examples, both good and bad AML practice and procedure
Ensure delegates understand the importance of the MLRO function concerning statutory requirements.
Consider the implications of MLR2017, 2019 & 6thMLD.
Consider PSC requirements and Trust registration.
Consider PEP criteria of Money Laundering and the single European Register.
How the MLRO must oversee and control the AML investigation process and how this is documented.
The need for regular and documented staff training.
The importance of an effective escalation process including SAR/STRs and the need for an effective Whistleblowing process.
The importance of the Annual (or more frequent) MLRO reporting.
How it all works in practice and where the pinch points often occur.

We have delivered FCC and money laundering reporting officer training programs to many leading organisations. This includes the world’s largest trade finance bank where the outsourced training program is entering its 8th year and Redcliffe remains the main provider of trainers in both the UK and overseas. We have also delivered extensive MLRO training courses to small and medium-sized firms.
Based on this Global Bank training program and our considerable experience in training small and medium-sized firms, we are certain we have as much and probably more experience delivering quality cutting-edge FCC & MLRO courses as anyone in the marketplace.
We believe this money laundering reporting officer workshop is one of the most up-to-date 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 for our MLRO training has always been excellent.

This money laundering reporting officer course is an absolute must for:

MLROs 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 derive considerable benefit from attending, as they are the ultimate risk owners
Front-line staff who have to “make this happen”
Anyone looking for either a refresher or an opportunity to hone their existing skills

As far as the creation of AML & FCC policies is concerned, the gatekeeper, the controller and the place where the “buck stops” is the MLRO. This is a critically important position within any firm covered by AML Rules. When it comes to the identification, detection, escalation, reporting, management and training of staff on Anti-Money Laundering procedures, it is the 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 money laundering reporting officer course is designed to fully explain the roles and responsibilities of an MLRO. It includes many interesting case studies based on real-life examples which will be used to enhance the learning experience. Delegate participation will be strongly encouraged throughout this MLRO training course, with many attendees telling 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 discharge your duties more effectively.

The trainer was very knowledgeable and tried to keep everybody engaged by relating examples to people's 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.

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