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  • FC-3.2 FC-3.2 Responsibilities of the MLRO

    • FC-3.2.1

      The MLRO is responsible for:

      (a) Establishing and maintaining the licensee's AML/CFT policies and procedures;
      (b) Ensuring that the licensee complies with the AML Law, any other applicable AML/CFT legislation and this Module;
      (c) Ensuring day-to-day compliance with the licensee's own internal AML/CFT policies and procedures;
      (d) Acting as the licensee's main point of contact in respect of handling internal suspicious transaction reports from the licensee's staff (refer to Section FC-4.1) and as the main contact for the Financial Intelligence Directorate, the CBB and other concerned bodies regarding AML/CFT;
      (e) Making external suspicious transaction reports to the Financial Intelligence Directorate and Compliance Directorate (refer to Section FC-4.2);
      (f) Taking reasonable steps to establish and maintain adequate arrangements for staff awareness and training on AML/CFT matters (whether internal or external), as per Chapter FC-5;
      (g) Producing annual reports on the effectiveness of the licensee's AML/CFT controls, for consideration by senior management, as per Paragraph FC-3.3.3;
      (h) On-going monitoring of what may, in his opinion, constitute high-risk customer accounts; and
      (i) Ensuring that the investment firm licensee maintains all necessary CDD, transactions, STR and staff training records for the required periods (refer to Section FC-6.1).
      Amended: January 2020
      ​​​​​​​Amended: October 2019
      Amended: October 2014
      Amended: July 2010
      Amended: January 2007