BaFin special audits: Key role of the Money Laundering Reporting Officer (MLRO)

BaFin’s findings from special audits: the money laundering officer holds a key position – here’s what you need to know!

In its special audits, BaFin identified the following key issues:

1. MLROs often take on additional responsibilities (e.g. securities compliance or tasks within the legal department).

2. MLROs are unable to fully perform their AML duties (e.g. backlogs in transaction monitoring or screening alerts; suspicious activity reports submitted too late).

3. MLRO warnings are sometimes ignored in favour of potential profit opportunities.

4. The regulatory framework is complex and its implementation is highly time-consuming.

5. Effective anti-money laundering (AML) compliance requires substantial resources.

What you need to keep in mind:

- MLROs must hold a strong and independent position within the company.

- Sufficient personnel, technical and financial resources are essential for effective AML compliance.

BaFin emphasises: These are responsibilities of the management!