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  • Money Laundering Reporting Officer (MLRO)

    • TC-1.1.15 [deleted]

      [Paragraph deleted in January 2011].

      Deleted: January 2011

    • TC-1.1.16

      In order to carry out the function of MLRO effectively, investment firm licensees must ensure that their MLRO:

      (a) Is a member of senior management of the licensee and has a sufficient level of seniority within the licensee, has the authority to act without interference from business line management and has direct access to the Board and senior management (where necessary);
      (b) [Subparagraph (b) combined with (a) in January 2011];
      (c) Has sufficient resources, including sufficient time and (if necessary) support staff, and has designated a replacement to carry out the function should the MLRO be unable to perform his duties;
      (d) Has unrestricted access to all transactional information relating to any financial services provided by the licensee to that customer, or any transactions conducted by the licensee on behalf of a customer;
      (e) Is provided with timely information needed to identify, analyse and effectively monitor customer accounts;
      (f) Has access to all customer due diligence information obtained by the licensee; and
      (g) Is resident in Bahrain.
      Amended: October 2013
      Amended: January 2011
      Adopted: July 2010

    • TC-1.1.17

      As outlined in Paragraph FC-3.2.1, the role and responsibilities of the MLRO involve, but are not limited to, the following:

      (a) Establishing and maintaining the investment firm licensee's Anti-Money Laundering (AML)/Combating the Financing of Terrorism (CFT) policies and procedures;
      (b) Ensuring compliance with the AML Law, any other applicable AML/CFT legislation as well as rules and guidance pertaining to Module FC;
      (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 for internal suspicious transaction reports from the licensee's staff, (refer to Section FC-4.1), and as the main contact for the Financial Intelligence Unit, the CBB and other concerned bodies regarding AML/CFT;
      (e) Making external suspicious transaction reports to the Financial Intelligence Unit 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 Section 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-3.3.1;
      (h) On-going monitoring of what may, in his opinion, constitute high-risk customer accounts; and
      (i) Maintaining all necessary customer due diligence (CDD), transactions, suspicious transaction reports (STR) and staff training records for the required periods (see Section FC-6.1).
      Amended: January 2016
      Amended: October 2013
      Adopted: July 2010