Money Laundering Reporting Officer
Every Licence Holder has to appoint a Money Laundering Reporting Officer (hereinafter referred to as the ‘MLRO‘) who should familiarize himself thoroughly, and who must ensure that all staff are familiarise, with the Prevention of Money Laundering Act, 1994, the Regulations and any relevant Guidance Notes. After having conducted its own due diligence checks, the MFSA will contact the proposed person outlining the nature of the role and asking such person to confirm, in writing, his understanding of the requirements and their acceptance of the responsibilities attached to the role of the MLRO.
The MLRO is to report any suspicious transactions to the Financial Intelligence Analysis Unit and should copy the MFSA, irrespective of whether the transaction is carried out or not. An internal reporting procedure is to be set up to ensure that staff can report any such transactions without hindrance and that clear reporting lines are in place. Senior management is to be made aware of such reports and should not be in a position to suppress them. The MLRO is to ensure that proper Know Your Customer procedures are in place. Particular care is to be taken as to identification procedures and records of corporate entities with authenticated copies of identification records being retained for all directors of such entities.