With renewed focus on the obligations surrounding Money Laundering Reporting Officers (MLROs), this week, FinanceMalta featured the Malta Financial Services Authority’s (MFSA) Head of Financial Crime Compliance, Anthony Eddington, on obligations surrounding the key role.

This follows tightening of reporting deadlines for MLROs by the Financial Intelligence Analysis Unit, as well as a clearly laid out document outlining the MFSA’s expectations of the role.

FinanceMalta is a public-private entity whose main objective is to promote the Malta’s financial services brand, both within, as well as outside Malta’s shores.

In a video message published to FinanceMalta’s social media platforms, Mr Eddington stressed that:

“The MLRO holds a key role in protecting the integrity of the financial system. Anybody taking on this role must understand the responsibilities attached to it and the consequences of not meeting those responsibilities.”

To this end, he reminded professionals “that is why the MFSA issued a guidance note in July outlining our expectations.”

He explained that an MLRO receives internal reports on possible instances of money laundering or funding of terrorism (ML/FT) and decides whether to submit a Suspicious Transaction Report to the FIAU.

For Subject Persons, licensed or otherwise, the role requires the prior approval of the MFSA.

Turning to the skill-set MLROs should have, Mr Eddinction stressed that a sound level of experience and knowledge in AML/CFT, Anti- Terrorism, Sanctions, Anti-Bribery and Corruption and all aspects of financial crime that could ultimately result in ML/FT.

“The MLRO should be of sufficient seniority and free from conflicts of interest to take independent action and should understand the Subject Person’s products, services and client base.

“MLROs are key in advising senior management about risk exposure that the Subject Person faces, and how to manage that risk. Subject Perons should ensure that their MLRO has sufficient time and resources to carry out their duties effectively.

“Before taking on the role of MLRO, one should be aware of the penalties to which they may be liable if found in breach of their AML/CFT obligations.”