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Core Competencies

The MLRO should have:

(a) A clear understanding of the role and responsibilities associated with the position;
(b) A good understanding of financial services activity relevant to the licensee and the wider industry and its regulatory environment;
(c) The relevant experience and qualifications to fulfill his responsibilities;
(d) Strong understanding of FATF guidelines and regulatory requirements in Bahrain;
(e) Experience in creating and executing an institution-wide AML strategy that integrates with broader risk management and compliance programs;
(f) Proficiency in developing and maintaining AML policies and procedures that align with regulatory requirements and industry best practices;
(g) Competence in updating policies in response to changes in the legal landscape, emerging financial crimes, or audit recommendations;
(h) Proficiency in developing, managing, and improving KYC and CDD, EDD frameworks to ensure the institution collects appropriate customer data;
(i) Expertise in using, configuring and overseeing AML software tools to monitor suspicious transactions, detect unusual activity patterns, and ensure compliance with regulatory reporting obligations;
(j) Ability to implement a risk-based approach to AML compliance, where resources are allocated according to the risk levels of different products, clients, or geographies;
(k) Expertise in conducting AML risk assessments to evaluate the inherent risks within the organization, and adjusting policies, procedures, and controls accordingly;
(l) Strong investigative skills to analyze complex customer transactions, payment flows, and financial patterns that might indicate potential money laundering activities;
(m) Knowledge of how to file Suspicious Transaction Reports (STRs) with relevant financial authorities; and
(n) Knowledge of international sanctions screening software and ensuring the company is not doing business with blacklisted entities or individuals.
Added: March 2025