MLROs are required to be officers within a subject person, thus have an existing employment relationship with the particular organisation, enjoying sufficient seniority and independence whilst holding relevant knowledge and experience within the AML/CFT sector.
As the function of an MLRO cannot be outsourced, and in view of the increasing demands placed on MLROs, BDO Malta may be engaged to provide ongoing support. The support is intended to assist MLROs with the fulfilment of his/her function in an ethical and proper manner, and in compliance with the legislative requirements and regulator’s expectations.
Support may be provided in relation to:
The MLRO appointment process;
The ongoing training and understanding of the AML/CFT legislative requirements;
The screening of high risk customers against reputable database sources;
The receipt and evaluation of reports from employees on knowledge or suspicion of money laundering or financing of terrorism (‘ML/FT’), or that a person may have been, is or may be connected to ML/FT;
The receipt of a request for information from the FIAU;
The proper documentation and submission of a SAR/STR; and
The reporting requirements, including the annual Risk Evaluation Questionnaires (REQs).
In providing AML Compliance support, BDO Malta takes on a sector-specific approach in relation to the particular compliance and regulatory monitoring obligations, in order to remain vigilant of all applicable rules and obligations imposed by the Regulator.