MLRO/MLCO – roles refined

With much upheaval in the AML environment following the Russian invasion of Ukraine, there is increased focus on the roles of the MLRO and MLCO within law firms. The SRA has issued fresh guidance on sanctions compliance and there are new inclusions to be inserted into policies, procedures and controls.

Of at least management seniority, the MLCO will be primarily responsible for those policies, controls and procedures, amending them and updating them as the rules change. They are also responsible for appointing the Money Laundering Reporting Officer (MLRO), supervising and vetting staff and undertaking an independent audit of the firm’s procedures.

As a senior member of a legal practice the MLRO has always been thought of as the fount of all knowledge when it comes to ML queries – but surely, the MLCO should take that role now? How do these two roles overlap? Can the same person be both? How well-resourced are the occupants of these two roles? How well should they be resourced?

This webinar will look at the following topics:

• New rules to be observed
• Roles and duties of the two positions
• Who can and should be the MLCO?
• Who can and should be an MLRO?
• What is the role of the MLCO?
  • PCPs
  • Vetting of staff
  • Audit of procedures
  • Overarching supervision and responsibility
• What is the role of the MLRO?
  • Receiving reports for consideration and transmission to NCA
  • Liaison with the regulator(s) and law enforcement
  • Contact point for ML queries
• Wider issues – cybercrime and business fraud
• Common issues for law firms
• Jobs, not job titles – how are the roles resourced by firms?