Deputy Money Laundering Reporting Officer (DMLRO)

Key responsibilities

Cover for the MLRO

• Act as MLRO during leave, illness, travel or any situation where the MLRO is conflicted out of a specific decision.
• When acting, receive and assess internal suspicion reports, decide whether to file, file STRs through goAML, and deal with the FIU.
• Hand over cases in writing when the MLRO returns, with full records of any decision taken.

Support to the MLRO and Compliance Officer

• Keep up to date with open internal reports, STRs and FIU correspondence so that cover can start immediately.
• Help maintain the STR register, evidence files and training records.
• Support training sessions and contribute to updates of the policies and procedures.
• Assist with preparation for audits and inspections.

Confidentiality

• Apply the same confidentiality and tipping-off controls as the MLRO.

Authority

• When acting as MLRO, the full authority and access of the MLRO, including direct access to the board.
• Access to the goAML account and to the records needed to perform the role.

Qualifications and experience

• Senior employee of similar standing to the MLRO, with sufficient experience and authority
• Degree in law, finance, accounting, compliance or a related field, or an equivalent professional qualification.
• [2 to 3] years of compliance or AML/CFT experience.
• Working knowledge of FIAMLA, the FIAML Regulations 2018, FIU guidance and goAML.
• Same AML/CFT training as the MLRO.

Skills and attributes

• Integrity, sound judgement and the ability to take over at short notice.
• Strict confidentiality.
• Clear written and spoken English and French.
• Fit and proper: no criminal convictions, with checks carried out on appointment.

Independence and conflicts

The DMLRO must have appropriate independence from customer-facing and revenue functions when acting as MLRO. If the DMLRO has a conflict on a particular case, the matter should go to the board or to another suitably senior person, and the reason must be recorded