What is a Money Laundering Reporting Officer?

A Money Laundering Reporting Officer (MLRO) is the individual within a regulated business responsible for overseeing AML compliance, receiving internal suspicious activity reports, and filing SARs with the relevant Financial Intelligence Unit. Appointing an MLRO is a legal requirement under the UK Money Laundering Regulations 2017 and equivalent legislation in other jurisdictions.

MLRO responsibilities

The MLRO is accountable for the firm's suspicious activity reporting. The role has three main parts.

Receiving internal reports

All staff should report suspicions to the MLRO, who evaluates whether the suspicion meets the threshold for external reporting.

Filing SARs

When the MLRO determines there are reasonable grounds for suspicion, they must file a SAR with the National Crime Agency (in the UK) or the equivalent FIU in other jurisdictions.

Oversight and training

The MLRO oversees the firm's AML policies and procedures, ensures staff receive appropriate training, and maintains the firm's risk assessment.

MLRO requirements for non-financial institutions

In smaller non-financial businesses, the MLRO is often a principal, partner, or director. The key requirements are sufficient seniority to make decisions about client relationships, authority to file SARs without obstruction, and adequate knowledge of AML obligations. FirmScreen supports MLROs with automated screening and audit trails that simplify oversight.

Related terms

  • SAR - the reports filed by the MLRO
  • AML - the compliance framework the MLRO oversees
  • CDD - processes the MLRO ensures are properly implemented