Universal Banking Soldier

The designation of an appropriate person to be the Money Laundering Compliance Officer (MLCO) in a financial institution is not an altogether new legal requirement, but one that has come under increased focus as Money Laundering and Terrorist Financing assume a new importance.

The reporting element of the MLCO’s role is to receive reports from members of staff of their knowledge or suspicions of money laundering, and, unless he decides that it is not, in fact, suspicious, his responsibility is to pass that information to the relevant authority.

When this post was created, different institutions made the appointment according to different criteria, dependent on such internal variables as their internal understanding of a suitable individual profile or competencies, the availability of suitable staff, and their interpretation of whose bailiwick the work fell in. In terms of the latter, some large organisations took the view that it was related