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Themed Examination Programme 2019 – The Role of the MLRO (it's out)


Themed Examination Programme 2019 – The Role of the MLRO (it's out)

In November 2018, the JFSC set out in high-level terms its planned thematic examination programme to be undertaken in 2019, within which the theme of the role of the Money Laundering Reporting Officer (MLRO) was identified.

The objective of the thematic examination was to review and assess, where relevant, the following:

  1. Whether the MLRO had appropriate independence, sufficient seniority and authority in the business;
  2. The MLRO’s assessment of internal SARs;
  3. The decision of whether or not to externalise a SAR was always documented appropriately;
  4. The Relevant Person’s governance, oversight and support of the MLRO; and
  5. The effectiveness of the Relevant Person’s internal control systems in respect of all the above.

There are 12 key findings

  1. Reporting Requirements
  2. Documenting Enquiries and Decisions
  3. Timeliness of Internal SAR Reporting
  4. Timeliness of External SAR Reporting
  5. Oversight by the Board / Management
  6. Acknowledgement of Internal SARs
  7. Apportionment and Awareness of Responsibilities
  8. Procedures
  9. Training and Awareness
  10. SAR Register
  11. Barriers to Reporting
  12. Independence

Out of the 12, there were two areas which reflected a considerable number of findings across Relevant Persons examined by the SEU and the PSU:

  1. Procedures; and
  2. Training and awareness

Please click here to read the report.


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