Exams and Associations

One of the main responsibilities of the UK MLRO is the provision (by himself or someone else) of adequate anti-money laundering (AML) training to “relevant employees” [Regulation 3] within his organisation. However, like the doctor who fails to notice his own illness, the MLRO may forget that he, more than anyone, falls squarely into this category, warns Sue Grossey.

Sue Grossey may be contacted on tel: +44 (0)1223 562636; email susan@thinkingaboutcrime.com

The interpretation of the phrase “relevant employees” is, like so many other decisions in this field, based on risk. Those employees who are more at risk of exposure to potential money laundering (such as account-opening or customer-facing staff) should be given more frequent, more detailed training than those who are less at risk (such as post-room staff or receptionists). By this measure, the MLRO himself should receive the most in-depth training, updated most often: after all, it is the MLRO who makes the final decision with regard to disclosures and the setting of AML policy and procedures. Moreover, the Financial Services Authority’s rules on Training and Competence require that firms are responsible for ensuring that their employees remain competent for the functions they carry out; since the MLRO has sole responsibility for Controlled Function 11, surely he needs the very best training to guarantee that his understanding of his responsibilities and of money laundering issues is sufficiently current and detailed.