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