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The Training Course

The increasing level of personal criminal liability for Money Laundering Reporting Officers (MLROs) presents a significant challenge for individuals taking on the role of MLRO, especially in the face of a vast array of complex parallel regulatory compliance frameworks affecting firms today. This includes inter alia Part 7 of the Proceeds of Crime Act 2002, Part 3 of the Terrorism Act 2000, the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (No. 692), the Financial Services Markets Act 2000, and the Criminal Finances Act 2017. Moreover, the interpretation of an array of national and international guidelines, as well as varying Know Your Customer (KYC) standards, can prove to be taxing on heavily burdened MLROs. This intermediate to advanced MLRO Operational Compliance training course has been designed to equip MLROs with all the information and knowledge they need to perform the role of MLRO fluently and with ease. The legal Expert Trainer will guide attendees through theoretical, practical, and operational aspects of the MLRO role, as well as leading attendees through the complex Anti-Money Laundering (AML) regulatory compliance frameworks, guidelines, and industry standards. 


Day 1


SESSION 1: A Review of the Nominated Officer Role and Responsibilities

  • The Role of the Nominated Officer (NO), NO Characteristics (Seniority, Risk Management Skills), NO Responsibilities.

  • Additional NO Responsibilities (Anti-Money Laundering (AML) Controls and Procedures, Record Keeping, Staff Training), and Counter the Financing of Terrorism (CFT) Controls and Procedures.

  • Customer Due Diligence (General, Enhanced, Simplified, Reliance and Record Keeping, Beneficial Ownership Information).

  • Risk Assessment, Policies and Procedures, Employee Screening and Training, Money Laundering Investigation and Law Enforcement, Civil and Criminal Penalties. 


SESSION 2: AML/CFT Legal Frameworks

  • An Overview of Part 7 of the Proceeds of Crime Act 2002 and Part 3 of the Terrorism Act 2000.

  • A Review of the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (No. 692).

  • An Overview of Section 59 Financial Services and Markets Act 2000 (FSMA) and Controlled Function Status.

  • Disclosure of Suspicious Activity Reports to the National Crime Agency and the Criminal Finances Act 2017. 


SESSION 3: AML/CFT Practical and Operational Compliance

  • A Guide to Legal Professional Privilege.

  • An Overview of the Guidelines to Prevent Transfers of Funds can be Abused for ML and TF.

  • An Overview of the Financial Conduct Authority (FCA) AML Annual Report (2015-2016; 2016-


  • A Review of Enforcement Cases relating to Money Laundering (Standard Bank PLC, Coutts, EFG, Turkish Bank (UK) Ltd, Guaranty Trust Bank (UK) Ltd, Habib Bank AG Zurich, Deutsche Bank). 


SESSION 4: AML and CFT Risk Assessments

  • Firm Wide Risk Assessment, Risk Factors, Risk Assessment taking into account the Size and Nature of the Business, European Banking Authority Guidelines on Risk Based Supervision.

  • Conducting a Risk-Based Approach (Focus on Outputs, Focus AML Resources, Seeking out Information on Money-Laundering Trends, Threats from External Sources).

  • Completing an AML/CFT Risk Assessment of the Business Utilising Risk Categories (Geographic Risk, Product Risk, Service Risk, Investor Risk, Channel Risk, Distribution Risk).

  • A Review of ‘FCA Financial Crime: A Guide for Firms’ and ‘Joint Money Laundering Steering Group Guidance’.