What is the role of the MLRO?

Every business regulated under the UK’s Money Laundering Regulations must appoint a person ultimately accountable for your business’s anti-money laundering (AML) reporting, ensuring that your staff are able to effectively and compliantly report any suspicions of money laundering – and that those reports are dealt with appropriately.

Whether you’re an accountant, solicitor or property professional, the MLRO plays a central role in keeping your business compliant and your reputation protected. Here’s what that role involves and how it fits within your wider compliance framework.

What the law says

Under Regulation 21 of the Money Laundering Regulations 2017, every regulated business must, where appropriate to its size and nature, appoint two key individuals:

• An officer responsible for compliance with the Regulations – often called the Money Laundering Compliance Officer (MLCO); and
• A nominated officer, responsible for receiving and assessing internal reports of suspicious activity – known in practice as the Money Laundering Reporting Officer (MLRO).

The MLRO’s legal duties sit within Regulation 21(3). They act as the nominated officer under the Proceeds of Crime Act 2002, deciding when a suspicious activity report (SAR) should be made to the National Crime Agency (NCA). The MLCO, by contrast, has broader responsibility for ensuring the business’s AML systems and controls meet the requirements of the Regulations. In smaller businesses, both roles are often performed by the same person.

The purpose of the MLRO

The MLRO acts as your business’ single point of contact for anti-money laundering matters. They oversee your compliance with the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 and act as the link between your business, your AML supervisor and law enforcement agencies such as the National Crime Agency (NCA).

Their responsibilities typically include:

• Receiving and assessing internal Suspicious Activity Reports (SARs)
• Deciding whether to submit a SAR to the NCA
• Maintaining and updating the business’s policies, controls and procedures (PCPs)
• Overseeing AML training and awareness
• Ensuring risk assessments and record-keeping are up to date
• Representing the business during AML reviews or inspections

The role carries personal accountability under the law, which means the MLRO must be both knowledgeable and empowered to act independently when compliance is at stake.

Reviewing and reporting suspicions

A key function of the MLRO is assessing internal reports of suspicious activity. When a staff member raises an internal SAR, the MLRO must:

1. Review the facts and supporting documentation
2. Decide whether the suspicion is reasonable and justified
3. Record the reasoning and any next steps taken
4. Submit an external SAR to the NCA where required

No transactions that might relate to the suspicious activity should proceed until consent is granted by the NCA or the appropriate statutory period has passed. The MLRO’s decision-making process must be documented to demonstrate compliance with the Proceeds of Crime Act (POCA).

Keeping your AML framework effective

The MLRO has overall responsibility for maintaining your business’s AML framework. This includes ensuring that written policies, controls and procedures are:

• Reviewed at least annually, or sooner if risks or regulations change
• Aligned with the business’s business-wide risk assessment
• Understood and followed by staff
• Supported by a clear audit trail

They must also make sure that AML policies are not treated as a formality. The most common compliance failures identified by regulators often stem from generic or outdated documentation that doesn’t reflect the actual risks faced by the business.

Overseeing training and awareness

Regulation 24 of the 2017 Regulations requires all staff to receive AML training, but effective MLROs go further. They make AML part of daily working life by:

• Tracking completion of training and refresher sessions
• Ensuring role-specific training for high-risk areas such as client onboarding or source-of-funds checks
• Providing updates when regulations or threats change
• Encouraging staff to raise concerns without fear of reprisal

Training and awareness are core to building a culture of compliance. Everyone in the business should understand the warning signs of money laundering and know when to escalate a concern.

Staying alert to new risks

The financial crime landscape changes quickly. The MLRO must keep the business informed of new threats, such as:

• Emerging technologies, including deepfakes and synthetic IDs
• Sanctions risks linked to geopolitical events
• Cryptocurrency-related activity and unregulated financial products
• Evolving typologies identified by supervisors and law enforcement

They must also ensure the business’ risk assessment and controls are updated to reflect these developments. The 2025 National Risk Assessment, for example, highlights weaknesses in many business’ ability to assess and respond to technological and cross-border risks. These changes are something MLROs are expected to address proactively.

Liaising with regulators and law enforcement

The MLRO is responsible for communicating with external bodies on behalf of the business, including:

• Supervisory authorities (e.g. HMRC, ICAEW, SRA)
• The National Crime Agency for SAR submissions
• Law enforcement or regulators during inspections or investigations

During a supervisory visit, the MLRO will usually be asked to provide evidence of:

• Training records and staff acknowledgements
• Current business and client risk assessments
• Policies and controls showing recent review dates
• SAR logs and decision records

Well-documented systems and a clear understanding of the business’ AML approach make these reviews smoother and demonstrate compliance in practice.

What makes a good MLRO?

The MLRO needs a mix of technical knowledge, professional judgement and communication skills. The most effective MLROs are:

• Authoritative – senior enough to influence decisions and stop risky work
• Knowledgeable – well-versed in AML law and current risks
• Approachable – trusted by colleagues to handle concerns fairly
• Organised – able to maintain records and monitor actions efficiently
• Independent – willing to challenge where necessary

They must also have enough time and resources to carry out the role effectively, something smaller practices sometimes overlook when appointing an MLRO alongside existing duties.

Why the MLRO role matters

The MLRO is not simply a compliance officer. They are the person who ensures your business is protected from the financial, regulatory and reputational fallout of money laundering. Their oversight helps prevent criminal abuse of professional services and provides assurance to supervisors that your business takes its obligations seriously.

For regulated professionals, a strong MLRO function is both a legal safeguard and a sign of good governance. By maintaining robust processes, encouraging openness, and staying alert to risk, the MLRO helps your business operate with confidence and integrity.