Money Laundering Reporting Officer MLRO Report Template | Systems and Controls | Breaches and Reports | Training and Assessments | Due Diligence and High Risk Clients | Template for FCA Applications and Authorised Firms – FCA Authorisations and Compliance

1 MLRO Annual Report

The Financial Conduct Authority (FCA) have specific regulatory rules and requirements set out in the ‘Senior Management Arrangements, Systems and Controls (SYSC)’ section of their handbook, which relate to financial crime and specifically anti-money laundering officer, controls, measures and audits. SYSC 6.3.7 also specifies that the appointed Money Laundering Reporting Officer (MLRO) is to ensure the appropriate provision of information to its governing body and senior management, including a report, at least annually, on the operation and effectiveness of the systems and controls put into place to enable it to identify, assess, monitor and manage money laundering risks.

[Your Company Name] (hereinafter referred to as the “Company”) produce an annual MLRO Report which is provided to Senior Management and made available to any regulating or governing body where applicable and/or requested. The report seeks to ensure the efficiency, effectiveness and adequacy of the AML/CFT measures, controls and systems in place and details any breaches, SAR’s, improvements and actions within the reporting period.

1.1 MLRO Annual Report Template

1 Company Details

MLRO Name: _______________

Date Report Compiled: _______________

Reporting Period: _______________

Date of Submission to Senior Management: _______________

Summary of Duties Performed by Appointed MLRO: _______________

Nominated Deputy in MLRO’s Absence: _______________

Other Roles Held by MLRO (e.g. Nominated Officer under Money Laundering Regulations, Proceeds of Crime Act and Terrorism Act etc)

___________________________________

2 Systems & Controls

a. Are the AML/CFT policy and procedure documents up to date?
YES/NO

b. Are they adequate to meet the firm’s needs & mitigate financial crime risks?
YES/NO

Describe how the adequacy of the AML documents was assessed e.g. methods, tools etc

___________________________________

c. Are they effective in meeting the regulatory & legal rules & requirements?
YES/NO

Describe how the effectiveness of the AML documents was assessed e.g. methods, tools etc

___________________________________

Detail any areas where the firm’s AML policies, procedures, systems and/or controls should be improved, and proposals for making appropriate improvements: –

___________________________________

e. Do the existing controls and measures ensure that your firm can identify, assess, monitor and manage money laundering risk?
YES/NO

f. Are client identification procedures effective and adequate?
YES/NO

g. Have due diligence checks been completed & retained for all new clients?
YES/NO

h. Are your Risk Management policies and procedures up to date?
YES/NO

i. Are they adequate to meet the firm’s needs & mitigate financial crime risks?
YES/NO

Describe how was the adequacy of the Risk Management documents was assessed

___________________________________

j. Are they effective in meeting the regulatory & legal rules & requirements?
YES/NO

Describe how the effectiveness of the Risk Management documents was assessed

___________________________________

Detail any areas where the firm’s Risk Management policies, procedures, systems and/or controls could/should be improved, and proposals for making appropriate improvements: –

3 Breaches & Reports

a. How Many Internal Suspicious Activity Reports (SAR’s) Were Completed? ____

b. Number of SAR’s Passed to the FCA/NCA? ____

Provide a summary of the SAR’s passed to the regulator(s)

___________________________________

c. Number of SAR’s NOT Passed to the FCA/NCA? ____

Provide the reason why any SAR’s were not referred to the regulator(s)

___________________________________

d. Were there any breaches of internal AML/CFT policies and/or procedures?
YES/NO

Provide details of any breaches and mitigating actions:

___________________________________

e. Were there any breaches of FCA regulations with regards to AML/CFT?
YES/NO

Provide details of any breaches and mitigating actions:

___________________________________

f. Were there any breaches of regulations/laws regarding AML/CFT
YES/NO

Provide details of any breaches and mitigating actions:

___________________________________

Outline the method used to identify suspicious transactions and/or activities: –

___________________________________

Describe arrangements for regular reporting, indicating frequency and those individuals within the firms and regulatory bodies to whom reports are made: –

___________________________________

Describe the scope and coverage of regular reports: –

___________________________________

4 Training & Assessments

a. Has appropriate and effective Financial Crime and AML training been provided to all employees and associated personnel?
YES/NO

b. Have all training materials been reviewed for compliance with current laws, regulations and legislation?
YES/NO

c. Are employees asked for feedback on the training content and delivery?
YES/NO

d. Are assessment papers used to test AML knowledge and understanding?
YES/NO

e. What was the date of the last content update/review for training materials?
MM/YY ____

f. Have all staff received the training within the past 6 months?
YES/NO

If any employee has not received the training, please provide details and reasons:

___________________________________

Please provide a summary of the AML/CFT training and assessment content: –

___________________________________

Detail any areas where the firm’s AML/CFT training program should be improved, and proposals for making appropriate improvements: –

___________________________________

Summarise the methods of training and quality checks performed for awareness and training with regards to AML/CFT/Financial Crime: –

___________________________________

Summarise the training, courses and materials used to ensure that the MLRO and any nominated deputy are up to date and compliant with AML/CFT/Financial Crime rules, regulations and laws: –

___________________________________

5 Due Diligence & High-Risk Clients

a. Is a due diligence checklist and questionnaire used for all new customers?
YES/NO

b. Are adequate/effective background checks performed on all new customers?
YES/NO

Provide details of the background checks performed and any external systems/providers used

___________________________________

c. Are adequate/effective background checks performed for all new employees?
YES/NO

d. How many customers does the firm have that it categorises as ‘high-risk’? ____

Provide a summary of the types of ‘high-risk’ customers

___________________________________

Describe the firm’s new product/service approval process (if applicable): –

___________________________________

Detail any business relationships where due diligence checks were not performed and provide reasons why (if applicable): –

___________________________________

6 Due Diligence & High-Risk Clients

a. Are adequate/effective monitoring and audit procedures and controls in place?
YES/NO

Provide details of the outcome of any monitoring or audit plans carried out

___________________________________

b. Based on the audit and monitoring outcomes, are the AML/CFT controls and measures deemed to be comprehensive and proportionate?
YES/NO

c. Are transaction monitoring processes adequate and effective?
YES/NO

d. Were ‘Source of Funds’ checks carried out?
YES/NO/NA

7 Summary

Summarise any regulatory/legislative changes during the reporting period and their impact on the firm’s systems, controls and measures: –

___________________________________

Summarise any impending and/or future regulatory/legislative changes that could impact the firm’s systems, controls and measures and suggestions for actions and/or mitigations: –

___________________________________

Indicate changes in activity and elements of the business that have had implications for money laundering controls: –

___________________________________

Provide a summary of any additions, improvements and/or suggestions that are to be presented to the Senior Management from the reporting period: –

___________________________________

Describe in order of priority, areas for remedial/preventative action, the action deemed necessary, and an expected timeframe for completion: –

___________________________________

To Be Completed by the MLRO

Have all questions been completed?
YES/NO

Have any associated documents been attached?
YES/NO

Signed: _______________________

Print Name: _______________________

Date: _______________________

To Be Completed by Senior Management Representative

Have all questions been completed?
YES/NO

Has the content contained in the report been reviewed and considered?
YES/NO

Has approval of any improvement actions been given?
YES/NO

Signed: _______________________

Print Name: _______________________

Date: _______________________