Practice area 04 · AML & Financial Crime Compliance
MLRO-as-a-Service
Experienced money laundering reporting officer capacity — as your appointed MLRO where the rules permit an external appointment, as deputy, or as structured support to the MLRO you employ.
Typical deliverables
- Engagement terms defining scope, time and authority
- Suspicion decision log and reporting workflow
- Periodic and annual MLRO reports
- Board management information pack
- Training plan and records
Overview
Why it matters
The MLRO is personally accountable for how a firm identifies and reports suspicion, and regulators assess the role closely at authorisation and at every inspection. For growing businesses, recruiting an experienced MLRO in the right location can take months — and an inexperienced appointment is a finding waiting to happen.
Whether the role can be outsourced depends on the regulator: some require the MLRO to be an employee, a director or resident in the jurisdiction; others accept an external appointment subject to conditions. We confirm what is permitted before proposing an arrangement, and structure it so that accountability stays clear.
Arrangements
Four ways to structure the role
- 1.
Appointed MLRO
An experienced professional holds the MLRO role for your firm, where the regulator accepts an external appointment, with a defined time commitment and reporting line to your board.
- 2.
Deputy MLRO
A documented deputy arrangement that covers absence and peaks in workload.
- 3.
MLRO support
Ongoing support to an MLRO you employ: second opinions on suspicious activity decisions, report drafting, management information and board reporting.
- 4.
Interim cover
Continuity during recruitment or after a departure, with a structured handover to the permanent appointee.
Scope
What the function covers
- 1.
Suspicion and reporting
Internal reports reviewed, decisions reasoned and recorded, and suspicious activity reports filed with the financial intelligence unit.
- 2.
Risk assessment ownership
Keeping the enterprise-wide risk assessment current and the controls aligned with it as products and markets change.
- 3.
Oversight of controls
Monitoring how customer due diligence, screening and transaction monitoring operate in practice, not only on paper.
- 4.
Board reporting
Periodic and annual MLRO reports with metrics, issues and remediation status, written for the board that must act on them.
- 5.
Training
Role-based AML/CFT training for staff and management, with records that evidence completion.
- 6.
Regulator and bank liaison
Responses to supervisory requests and to the AML questions banks and payment partners raise in due diligence and periodic reviews.
Considerations
Delivery depends on local requirements
AML & Financial Crime Compliance is one of our cross-jurisdiction capabilities, but MLRO-as-a-Service is not offered on the same basis everywhere. Whether and how the role can be provided depends on the local requirements that apply to your firm, including, where relevant, the points below. We confirm them before proposing a delivery model; in every model, the board remains responsible for the AML/CFT framework.
- Appointment requirements: who may hold the role, for example an employee or a director of the firm.
- Residency requirements for the MLRO or deputy.
- Restrictions on outsourcing the function, or conditions attached to it.
- Regulator approval of the appointment, or notification to the regulator.
Industries
Where we apply it
- 01iGaming & GamingB2C operators, B2B suppliers, platforms, aggregators and affiliates.
- 02Fintech & PaymentsPayment and e-money institutions, PSPs and acquirers, payment facilitators and embedded finance.
- 03Crypto & Digital AssetsCASPs and VASPs, exchanges, custodians, wallets, token projects and crypto payments.
- 04Forex & InvestmentsForex and CFD brokers, investment firms, trading and investment platforms.
- 05Digital Platforms & MarketplacesOnline marketplaces, platform operators and intermediary business models.
- 07High-Risk & Regulated Digital BusinessesBusiness models that banks, payment providers and regulators treat with enhanced scrutiny.
Questions
Frequently asked
Can the MLRO role be outsourced in our jurisdiction?
It depends on the regulator and the type of firm. We check the specific requirements — including residency and employment conditions — before proposing an arrangement, and design a support model instead where outsourcing is not permitted.
How much time does an outsourced MLRO spend on our business?
The time commitment is agreed in the engagement. It reflects your volumes, risk profile and regulatory expectations, and it is reviewed as the business grows.
Related
Part of AML & Financial Crime Compliance
- 04AML & Financial Crime ComplianceAML/CFT programmes, MLRO-as-a-Service, independent AML/CFT audits, risk assessments, monitoring, sanctions and inspection support.
- Independent AML/CFT AuditIndependent testing of your AML/CFT framework's design and effectiveness, with rated findings and a remediation plan.
Discuss your matter with a senior advisor.
Share a few details about your business and plans. We will come back to arrange a confidential initial conversation.