AML & Financial Crime Compliance
MLRO-as-a-Service
Experienced money laundering reporting officer capacity: an appointed MLRO, a deputy or support to your own MLRO, with clear accountability.
Typical deliverables
- Engagement terms defining scope, time and authority
- Suspicion decision log and reporting workflow that evidence each decision
- Periodic and annual MLRO reports the board can act on
- Board management information pack
- Training plan and records that evidence completion
Overview
Why it matters
MLRO-as-a-Service brings experienced capacity to a role that regulators assess closely at authorisation and at every inspection, and in which the MLRO is personally accountable for how the firm identifies and reports suspicion. For a growing business, it is a practical alternative to relying on a recruitment search in the right location, which can take months.
We propose the arrangement that fits your firm and your regulator's rules — an appointed MLRO, a deputy, interim cover or support to the MLRO you employ — and structure it so that accountability stays clear and each reporting decision is documented for supervisory review.
Arrangements
Four ways to structure the role
Appointed MLRO
An experienced professional holds the MLRO role for your firm, with a defined time commitment and reporting line to your board.
Deputy MLRO
A documented deputy arrangement that covers absence and peaks in workload, so reporting decisions are not held up.
MLRO support
Ongoing support to an MLRO you employ: second opinions on suspicious activity decisions, report drafting, management information and board reporting.
Interim cover
Continuity during recruitment or after a departure, with a structured handover to the permanent appointee.
Scope
What the function covers
Suspicion and reporting
Internal reports reviewed, decisions reasoned and recorded, and suspicious activity reports filed with the financial intelligence unit.
Risk assessment ownership
Keeping the enterprise-wide risk assessment current and the controls aligned with it as products and markets change.
Oversight of controls
Monitoring how customer due diligence, screening and transaction monitoring operate in practice, not only on paper.
Board reporting
Periodic and annual MLRO reports with metrics, issues and remediation status, written for the board that must act on them.
Training
Role-based AML/CFT training for staff and management, with records that evidence completion.
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
Built around your regulator's rules
We build the arrangement on the rules that apply to your firm, including, where relevant, the points below. 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
- iGaming & GamingB2C operators, B2B suppliers, platforms, aggregators and affiliates.
- Fintech & PaymentsPayment and e-money institutions, PSPs and acquirers, payment facilitators and embedded finance.
- Crypto & Digital AssetsCASPs and VASPs, exchanges, custodians, wallets, token projects and crypto payments.
- Forex & InvestmentsForex and CFD brokers, investment firms, trading and investment platforms.
- Digital Platforms & MarketplacesOnline marketplaces, digital platforms, multi-sided platforms and digital service operators.
Questions
Frequently asked
Can the MLRO role be outsourced in our jurisdiction?
We check that first, against the rules for your regulator and type of firm. Where an external appointment is permitted, we act as your appointed MLRO, deputy MLRO or interim cover; where the role must be held by an employee or a resident, we support the MLRO you appoint, so you have experienced capacity either way.
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
- AML & Financial Crime ComplianceAML/CFT programmes, MLRO-as-a-Service, independent AML/CFT audits, risk assessments, monitoring, sanctions and inspection support.
- Independent AML/CFT AuditSee how your AML/CFT controls perform on real files and alerts, through independent testing that ends in a shareable report and a remediation plan.
Need an experienced MLRO in place?
Tell us your licence, jurisdiction and volumes. We recommend the arrangement that fits your firm and its regulator, then send a written proposal with scope, timetable and fee.