Quality control: UK regulator reviews MLRO applications and competence

Denis O’Connor, a Fellow of both the Institute of Chartered Accountants in England & Wales and the Chartered Institute of Securities and Investment, was a member of the British Bankers’ Association Money Laundering Committee from 2003-10 and a member of the Joint Money Laundering Steering Group’s Board and Editorial Panel between 2010 and 2016. He has been a frequent speaker at industry conferences on financial crime issues, both in the UK and abroad.

Knowledge and understanding of anti-money laundering obligations might be counted basic qualification for the UK Money Laundering Reporting Officer role but must it be a dedicated position, full-time, with or without external support, and UK-based, and what is the regulatory risk it carries? Denis O’Connor considers the Financial Conduct Authority’s answers, in practice.