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ARTICLE · 12 APRIL 2022

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The MLRO – Common Concerns

CSB Group
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In order to address concerns and queries which are regularly received, on the 6th of April 2022, the Financial Intelligence Analysis Unit issued a guidance note to provide further guidance on the role of the Money Laundering Reporting Officer.

MaltaGovernment, Public Sector
Francesca Anastasi
Francesca Anastasi
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In order to address concerns and queries which are regularly received, on the 6th of April 2022, the Financial Intelligence Analysis Unit (the 'FIAU') issued a guidance note to provide further guidance on the role of the Money Laundering Reporting Officer (the 'MLRO').

Independence and Autonomy

It is of significant importance that the MLRO acts autonomously when executing the functions linked to this role. Even though, in line with the Implementing Procedures Part I (the 'IP'), the MLRO is permitted to communicate directly with the Board of Directors, one still remains accountable for any decision which is taken during the fulfilment of the MLRO functions.

No one within the subject person should pressure the MLRO to not exercise their own discretion. Whilst the MLRO may certainly seek advice or consult with respect to internal reports it still remains entirely up to the MLRO whether such report shall be submitted to the FIAU or otherwise.

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