The MLRO is the key reference point of the business when it
comes to AML/CFT.
The MLRO is the key reference point of the business when
it comes to AML/CFT. This entails an agile approach as one
navigates through the professional and personal dynamics synonymous
with the role.
Independence & Autonomy
The independence and autonomy of the MLRO stems from seniority
and authority. Any actions taken or detained should be at the
discretion of the MLRO, who should not be influenced in the
decision-making process. Access to the data and resources required
to perform the role effectively should be unrestricted, and the
MLRO should have the freedom to share all relevant data with the
regulators. Obliged entities can support the MLRO's
independence and autonomy by endorsing a shared understanding of
the legal obligations for persons acting as MLROs across the
business, and by engaging independent auditors to review and test
the performance of the MLRO to provide assurance
