Money laundering reporting officer
MLRO, Geldwäschebeauftragter
Other languages: Deutsch · Français · Español
The person at management level responsible for compliance with anti-money-laundering rules; mandatory in Germany for certain obliged entities under section 7 GwG.
The officer receives internal suspicion reports, decides on reports to the authorities, is responsible for the risk analysis and training and reports directly to senior management. In Switzerland, the internal anti-money-laundering unit has a comparable function.
In practice
The function only works if it has the necessary powers: unrestricted access to client data and documents, a direct reporting line to senior management and a designated deputy. Day to day, the officer coordinates the risk analysis, training and internal reports and decides on reports to the financial intelligence unit. For smaller family offices, a carefully documented outsourcing is possible, but responsibility remains with senior management.
Distinctions and common mistakes
The officer carries operational responsibility; overall responsibility remains with senior management. Typical mistakes are a missing deputy, assigning the function to a person who also conducts the business to be monitored, and missing powers: the officer needs unhindered access to all information required for the role.
Relevant in: Germany · Austria
Related terms
- Suspicious activity report
- A report by an obliged entity to the national financial intelligence unit when there are indications of money laundering or terrorist financing.
- Risk-based approach
- Principle under which the scope and depth of due diligence depend on the specific money-laundering risk.
Mentioned in these guides
- Internal directives on combating money launderingWhat internal anti-money laundering directives in a family office must cover: responsibilities, risk criteria, processes, reporting, training and controls.