AML/CFTR 2.3.4 Particular responsibilities of MLRO

(1) The MLRO for a firm is responsible for:
(a) receiving, investigating and assessing internal suspicious transaction reports for the firm;
(b) making suspicious transaction reports to the FIU and telling the Regulator about them;
(c) acting as central point of contact between the firm, and the FIU, the Regulator and other State authorities, in relation to AML and CFT issues;
(d) responding promptly to any request for information by the FIU, the Regulator and other State authorities in relation to AML and CFT issues;
(e) receiving and acting on government, regulatory and international findings about AML and CFT issues;
(f) monitoring the appropriateness and effectiveness of the firm's AML/CFT training programme;
(g) reporting to the firm's senior management on AML and CFT issues;
(h) keeping the Deputy MLRO informed of significant AML/CFT developments (whether internal or external); and
(i) exercising any other functions given to the MLRO, whether under the AML/CFT Law, these rules or otherwise.
(2) If the Regulator issues guidance, the MLRO must bring it to the attention of the firm's senior management. The firm must make and keep a record of:
(a) whether the senior management took the guidance into account;
(b) any action that the senior management took as a result; and
(c) the reasons for taking or not taking action.
Derived by QFCRA RM/2019-8 (as from 1st February 2020)