An MLRO and an AML compliance officer can be the same person, but the two titles come from different rules. The Proceeds of Crime Act 2002 and the Money Laundering Regulations 2017 speak of a nominated officer, who decides whether a staff report of suspicion goes to the authorities.
The MLRO title comes from the FCA's rules (SYSC 6.3.9R), where the role also covers oversight of the firm's anti money laundering systems and controls. The officer responsible for compliance under regulation 21(1)(a) answers for the regulations as a whole. The FCA expects that one individual can hold all of these roles (FCG 3.2).
What is an MLRO, and is it the same as the nominated officer?
They can be one person, with no separate notification to the FCA (FCG 3.2). Since 26 June 2017 the duty has sat in regulation 21(3) of the Money Laundering Regulations 2017: "An individual in the relevant person's firm must be appointed as a nominated officer."
Under the FCA's senior managers and certification regime, acting as MLRO is the money laundering reporting function, SMF17 (SUP 10C.6), which SUP 10C Annex 1 applies to most firm types but not to all. The holder needs FCA approval under section 59 of the Financial Services and Markets Act 2000, applied for on Form A.
SYSC 6.3.9R asks for an MLRO with "a level of authority and independence within the firm" and names no qualification; a certificate such as ACAMS's CAMS or an ICA certificate is optional. The director or senior manager with overall responsibility for the anti money laundering systems may also be the MLRO (SYSC 6.3.8R).
If your group's MLRO sits abroad, the UK firm still needs a nominated officer of its own, because regulation 21(3) asks for an individual "in the relevant person's firm" and SYSC 6.3.10G says the FCA expects the MLRO to be "based in the United Kingdom".
What does an MLRO decide?
Take a request for a defense against money laundering (DAML). The National Crime Agency's guidance rejects one asking "To use the funds in the account at the direction of the customer", because it is "too broad and not specified for either time, value or activity". It accepts one that names the act and gives the bank details: "I seek a defence to transfer the closing balance of £5,000 from the client's account to their nominated account" (UKFIU guidance on DAMLs, December 2025, version 1.1, p. 11).
Asking for a defense is one of four MLRO responsibilities:
- Consider each internal report. Weigh it against everything the firm holds, the KYC and customer due diligence (CDD) file included, and decide whether it gives knowledge, suspicion or reasonable grounds for either (reg 21(5)).
- Disclose to the NCA. Send a suspicious activity report to its UK Financial Intelligence Unit (UKFIU) as soon as practicable.
- Ask for a defense first. Before a suspect transaction, request a DAML and wait out the notice period in POCA s335.
- Report to the board. At least once a year, on how well the controls work (SYSC 6.3.7G).
One challenge MLROs face is volume. In 2025 to 2026 the UKFIU received 896,414 SARs and 44,553 DAML requests; it refused 3,943 of those requests, and £422.3 million was denied to suspected criminals through them (SARs Annual Report, pp. 4 and 12).
In complead, formerly Sanction Scanner, the workspace for compliance officers drafts the SAR or STR from the case record, and the MLRO reviews and signs it.
Can an MLRO be prosecuted?
Yes. Under POCA s331, a nominated officer commits an offense when, among other conditions, a staff disclosure gives knowledge, suspicion or reasonable grounds for either that someone is laundering money, and the officer, with no reasonable excuse, does not pass it to the NCA as soon as practicable. An MLRO who should have suspected is therefore exposed too. The maximum on indictment is five years in prison, a fine or both (s334(2)).
When is an MLRO required by law, and which businesses need one?
Every relevant person listed in regulation 8(2) must appoint a nominated officer:
- Credit and financial institutions. The accounts criminal money passes through.
- Auditors, accountants, tax advisers, insolvency practitioners and independent legal professionals. Client money and transactions; lawyers and accountants are among the DNFBPs.
- Trust or company service providers, estate and letting agents. Companies and property changing hands.
- High value dealers, casinos and art market participants. Large payments, some in cash.
- Cryptoasset exchange providers and custodian wallet providers. Crypto turned into money or held for customers.
An individual who "neither employs nor acts in association with any other person" is exempt (reg 21(6)), and SYSC 6.3.9R leaves out a sole trader with no employees. The supervisor learns who the nominated officer is within 14 days of the appointment (reg 21(4)). Electronic money issuers and payment service providers also name an individual to monitor and manage compliance (reg 21(7)). In a group, FCG 3.2 lists as poor practice an MLRO who "has not considered whether group policy adequately addresses UK AML obligations".
What is the MLRO called in the EU, the US and India?
Table 1. The MLRO role by jurisdiction (as of October 2026).
| Jurisdiction | Title and legal basis | Who appoints | What the person decides | Status |
|---|---|---|---|---|
| UK | Nominated officer (MLR reg 21(3)); MLRO, SMF17, in most firms under the senior managers regime | The firm, with FCA approval for SMF17 | Which staff reports go to the UKFIU; DAML requests; the annual board report | In force; reg 21 last amended 1 September 2022 |
| EU | Compliance officer, beside a compliance manager on the management body (AMLR Art 11) | The management body | Policies and controls day to day; reporting suspicious transactions to the FIU | Applies from 10 July 2027; national laws until then |
| US | The individual for "coordinating and monitoring" compliance (31 CFR 1020.210) | The bank | Coordinates and monitors compliance day to day; the bank files the SARs (31 CFR 1020.320) | In force (eCFR, 1 October 2026) |
| India | Principal Officer and Designated Director (RBI Know Your Customer Directions, 2025, paras 14 and 15) | The bank; the board nominates the Designated Director | Principal Officer: compliance, transaction monitoring and reporting under the law; never the Designated Director | Updated 1 October 2026 (commercial banks) |
The EU text is a regulation, so from 10 July 2027 Article 11 applies directly in every member state. Where size and low risk justify it, a firm in a group may use another group entity's compliance officer; the UK text asks for an individual "in the relevant person's firm".
What changed in 2026.
- SARs Annual Report 2025 to 2026: DAML requests fell about 23 percent, which the UKFIU puts "primarily" down to the July 2025 rise in the threshold from £1,000 to £3,000 (POCA s339A).
- 18 June: HM Treasury published the outcome of its consultation on the powers the FCA needs to supervise legal, accountancy and trust and company service providers, whose anti money laundering supervision it is to take over.
- 30 June: the amendments of S.I. 2026/621 to the Money Laundering Regulations 2017 took effect for most purposes; none touches regulation 21.
If you run a UK firm, the next step is to appoint one: who covers when the MLRO is away and, in an FCA firm, how the SMF17 application on Form A runs. Regulation 21, SYSC 6.3 and FCG 3.2 never use the title "deputy MLRO", so the duties stay with the nominated officer the firm appointed and notified.
Related terms
- AML compliance officer. The officer accountable for an AML program's policies, controls and training.
- Suspicious activity report. The report a firm sends its financial intelligence unit about suspected laundering.
- DNFBP. Lawyers, accountants, estate agents and other non financial businesses that carry AML duties.
- Compliance. A firm's work to meet the laws and rules that apply to it.
- Anti money laundering. The body of law and firm controls aimed at stopping criminal money from looking clean.
- Money laundering. Hiding, moving, using or spending the proceeds of crime while knowing or suspecting their source.
How this entry was checked. Onur Taner, Customer Success Manager at complead, drafted the entry. Ufuk Gürdaş reviews it as Compliance Specialist; the reviewer is MASAK certified as a compliance officer, has an MBA in Auditing and the ICA Certificate in Compliance, and has spent over 10 years in compliance at banks and fintech firms (last reviewed: 28 October 2026). The definition follows the UK legal role of the nominated officer, which the MLRO title grew out of. On 28 October 2026 each statement was traced to the Proceeds of Crime Act 2002 (sections 331, 334, 335 and 339A), the Money Laundering Regulations 2017 (regulations 1, 8 and 21) and their 2026 amendment, section 59 of the Financial Services and Markets Act 2000, the FCA Handbook (SYSC 6.3, SUP 10C and FCG 3.2), the National Crime Agency's DAML guidance and SARs Annual Report, 31 CFR 1020.210 and 1020.320, Regulation (EU) 2024/1624 and the Reserve Bank of India's 2025 Know Your Customer Directions.
