• INDI Part S1.7 INDI Part S1.7 MLRO function competencies


    1 The competencies in this Part for the MLRO function are in addition to any requirements under other Rules for the function. See in particular AML/CFTR, rule 2.3.2, and AMLG, rule 2.3.2.
    2 The level of an individual's competencies must be commensurate to the nature and complexity of his or her role in the firm and the regulated activity or activities that the firm conducts (see rule 3.1.3 (4)).
    Derived from QFCRA RM/2014-5 (as from 1st January 2015)

    • INDI Division S1.7.A Skills

      S1.7.1 Gather and disseminate information about AML/CFT requirements in the firm
      S1.7.2 Identify the implications of AML/CFT measures for the business conducted by the firm
      S1.7.3 Assess and mitigate the money laundering and terrorist financing risks relevant to the firm
      S1.7.4 Identify improvements to the implementation of AML/CFT measures in the firm
      S1.7.5 Design an AML/CFT programme
      S1.7.6 Communicate and implement the firm's AML/CFT policy
      S1.7.7 Assist in developing the compliance culture of the firm
      S1.7.8 Design and oversee procedural controls to monitor money laundering and terrorist financing risks in the firm
      S1.7.9 Report progress in securing AML/CFT outcomes
      S1.7.10 Assist senior management in ensuring their staff comply with AML/CFT measures
      S1.7.11 Develop and maintain AML/CFT records for the firm (including documentary evidence of compliance, records for customers and transactions, and reporting and training records)
      S1.7.12 Advise and guide staff on AML/CFT
      S1.7.13 Conduct a business risk assessment
      S1.7.14 Plan and deliver AML/CFT training
      S1.7.15 Respond to requests to contribute to consultations
      S1.7.16 Handle requests for financial information from the relevant authorities
      S1.7.17 Design and monitor an internal reporting system for suspicious transactions and activities
      S1.7.18 Identify, investigate and resolve non-compliant activity within the firm
      S1.7.19 Report suspicious financial activity to the relevant authorities
      Derived from QFCRA RM/2014-5 (as from 1st January 2015)

    • INDI Division S1.7.B Knowledge

      S1.7.21 The CISI Regulatory qualification
      S1.7.22 A recognised MLRO function professional qualification at certificate level, or any other qualification that the firm is satisfied is appropriate for the role

      Note 1 In considering a qualification for clause S1.7.22, qualifications that are recognised as appropriate for the role by another regulator may be taken into account. See rule 3.1.4 (3).

      Note 2 The firm must record and retain its assessment and any supporting evidence (see rule 3.1.4 (4)).
      Derived from QFCRA RM/2014-5 (as from 1st January 2015)

    • INDI Division S1.7.C Experience and other elements

      S1.7.31 Appropriate level of experience and seniority for the role
      Derived from QFCRA RM/2014-5 (as from 1st January 2015)