The role of the Money Laundering Reporting Officer (“MLRO”) is arguably one of the most frequently asked about topics when it comes to questions directed to the Financial Intelligence Analysis Unit (“FIAU”).
In the course of answering and addressing these questions, the FIAU has gained practical insight into how different requirements create certain challenges, and on the interpretation of these notions in practice. In addition, reference to laws such as the Prevention of Money Laundering and Funding of Terrorism Regulations (“PMLFTR”) and the Implementing Procedures issued by the FIAU, are always made when replying to said questions.
With the aim of aiding subject persons to fulfil their need to understand the particular role of the MLRO and other related matters, the FIAU compiled its replies in one document, the Guidance Note. The FIAU reminds subject persons that this is not a standalone document but is to be read together with the PMLFTR and the applicable Implementing Procedures, including any sector specific Implementing Procedures that may contain directions on the role of the MLRO.
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