A Money Laundering Reporting Officer (MLRO), generally known as the AML compliance officer, is a vital element in a company’s framework for Anti-Money Laundering & Combating the Financing of Terrorism (AML / CFT). As per Article 20 of Cabinet Decision, No 10 of 2019 on AML-CFT, financial institutions and Designated Non-financial Businesses and Professions (DNFBPs such as real estate agents, auditors, trust and corporate service providers, dealers of precious metals and stones) are required to appoint an MLRO. An MLRO is chiefly responsible for a company’s AML-CFT policies and programmes.

The officer serving as an MLRO in the UAE needs to make informed decisions as to whether criminals are using the business to launder the proceeds of criminal activity or provide financial support to terrorists. If any risk of ML-CT is detected, the MLRO must alert the management and regulatory authorities through various mandatory reports. You can consult with AML consultants in Dubai before appointing an MLRO in your company.

In this article, we will dive into why an MLRO is critical to your company’s AML compliance framework. We will also discuss the role of an MLRO and the responsibilities attached to taking on the role. Keep reading to get valuable insights:

What Are the Key Tasks of an MLRO in the UAE?

Apart from ensuring their organisation’s compliance with AML-CFT controls, MLROs deal with any information, knowledge, or suspicion of money laundering and properly disclose such matters to the supervisory authority. As per Article 21 of Cabinet Decision No. (10) of 2019, an MLRO is required to perform the following tasks:

1. Detect transactions related to any ML-CT crime
2. Review, scrutinise and study records, receive data concerning Suspicious Transactions, and make decisions to either notify the Financial Intelligence Unit (FIU) or maintain the transaction with the reasons for maintaining while maintaining complete confidentiality
3. Review the internal rules and procedures related to ML-CT and their consistency with the UAE AML Law; assess the extent to which the company is committed to the application of such rules and procedures, propose what is needed to update and develop these rules and procedures, prepare and submit semi-annual reports on these points to senior management, and send a copy of that report to the relevant Supervisory Authority enclosed with senior management remarks and decisions
4. Prepare, execute and document ongoing training and development programs and plans for the organisation’s staff on Money Laundering and the Financing of Terrorism and Financing of Illegal organisations, and the means to combat them
5. Collaborate with the Supervisory Authority and FIU, provide them with all requested data, and allow their authorised employees to view the necessary records and documents that will allow them to perform their duties

What Makes an Effective MLRO?

The job of an MLRO in the UAE is to serve as the focal point for all activities related to AML-CFT. However, not all people can make a good MLRO in the UAE. Businesses can consult with AML consultants in Dubai for appointing an MLRO. The person acting as an MLRO should tick the following:

1. In a company, the MLRO must have sufficient freedom to act on his authority and to be informed of any relevant knowledge or suspicion in the organisation
2. An MLRO must have a sufficient level of seniority within the company
3. Companies should give an MLRO sufficient resources, time and support staff
4. MLRO should be able to monitor the day-to-day operation of the company’s anti-money laundering policies
5. The MLRO should respond promptly to any reasonable request for information made by the regulatory authorities
6. An MLRO must have the ability to review AML-CFT reports and determine if there are any grounds to submit a Suspicious Transaction Report (STR) to the FIU

Why Is an MLRO Critical to Your Company?

Since the advent of the AML-CFT framework in the UAE, the MLRO has assumed one of the most critical roles in a company. This is because the reports issued by the MLRO have a significant impact on a company’s relationship with its customers. MLROs ensure that the company can access all client files and business information to make necessary decisions and actions.

The decisions made by an MLRO may result in significant legal ramifications such as civil and criminal penalties. Moreover, if a company’s AML-CFT framework is found to be weak, the MLRO will be held responsible. In such cases, businesses can consult with AML consultants in Dubai to strengthen their AML-CFT policies, controls and procedures.

Ensure AML Compliance through the Best AML Consultants in Dubai, UAE

An MLRO is completely responsible for a company’s AML-CFT processes, proceduresq and controls. You can strengthen your company’s AML-CFT framework with the help of the best AML consultants in Dubai such as Jitendra Chartered Accountants (JCA). JCA is one of the top providers of AML consulting services in Dubai with years of experience.

Our AML advisers in Dubai are highly qualified and come with impressive experience and expertise. JCA provides services such as implementing AML Policy and Procedures, assessment of tools and controls design, review of current AML Policy, planning of AML-CFT framework, AML audit and reporting, AML training for the staff, Assistance with goAML registration and AML penalty appeal services.