6th April 2022

One of the main topics about which the Financial Intelligence Analysis Unit (FIAU) receives questions is that of the Money Laundering Reporting Officer (MLRO).  In replying to these questions, the FIAU has gained insight into how certain requirements raise difficulties and it has been required to clarify how they are to be interpreted and applied in practice. Furthermore, it has at times had to clarify whether certain arrangements are permissible or otherwise, in terms of the PMLFTR and the Implementing Procedures.  To support subject persons in their understanding of the role of the MLRO and related matters, the FIAU has condensed these replies in a single document and the information is being made available to all subject persons and MLROs. The Guidance Note may be accessed by clicking on the below link.

This Note is not a standalone document but is to be read together with the PMLFTR and the applicable Implementing Procedures, including any sector specific Implementing Procedures that may contain directions on the MLRO. 

Questions related to the said Guidance Note are to be sent on the following email address – [email protected].