Some obligated parties have to appoint Money Laundering Reporting Officers (MLRO), which ties up resources and causes considerable additional costs. In addition, you have to continuously audit your internal risk management systems, which requires qualified contact persons for questions on the topic of anti money laundering compliance, who offer practical help for sector-specific problems through practical experience. These challenges are hardly manageable for many companies.
We provide you with certified money laundering reporting officers and support you with practical advice and independent audits.
Outsource the appointment of certified MLROs and their deputies and protect yourself from fines and penalties.
Protect yourself by filing standardised and professionally verified money laundering suspicious activity reports.
Create a way to submit anonymous reports with the MLRO, including case management and evaluation according to the highest standards (ISO 27001).
Have your internal security measures audited by independent auditors and benefit from direct improvement measures.
Our money laundering reporting officers are experienced experts in dealing with authorities and in accompanying audits. We also offer all the necessary tools to monitor and maintain your anti money laundering compliance. In this way, we ensure quick and easy implementation and compliance with your obligations.
Appointing the Money-Laundering Reporting Officer (MLRO) & Deputy
Experts for all aspects of your anti money laundering compliance
Your risk management and other internal safeguards
MLROs are subject to special labour rights that do not apply to external service providers
Certification courses for MLROs usually cost several thousand euros.
the MLRO training is valid, after that the knowledge must be refreshed at a charge
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Money laundering reporting officers are responsible for compliance with all money laundering regulations within your company. This includes, for example, the training of employees, the provision of a whistleblower portal, the processing of suspicious cases and much more.
In addition, the money laundering reporting officer is responsible for communicating with the prosecution authorities, the FIU and the supervisory authorities. In this context, he is also responsible for submitting suspicious activity reports or for responding to requests for information from the FIU. In addition, he must report to the management on the company's anti money laundering compliance.
According to the Money Laundering Act, obligated persons must appoint a money laundering reporting officer at management level and a deputy in accordance with §2 paragraph 1 numbers 1-3, 6, 7, 9 and 15 GWG. These are, among others and with possible exceptions:
No. 1 - Credit institutions
No. 2 - financial services institutions
No. 3 - payment institutions and electronic money institutions
No. 6 - financial undertakings
No. 7 - insurance undertakings
No. 9 - Capital management companies
No. 15 - Organisers and brokers of games of chance
In addition, the supervisory authorities may require obligated persons pursuant to § 2 paragraph 1 numbers 4, 5, 8, 10 to 14 and 16 to appoint money laundering reporting officers if they deem this appropriate. These include, but are not limited to, and with possible exceptions:
No. 4 - payment and electronic money agents.
No. 5 - self-employed persons distributing or redeeming electronic money
No. 8 - Insurance intermediaries
No. 10 - Lawyers, chamber attorneys, patent attorneys and notaries public
No. 14 - Real estate agents
No. 16 - Dealers in goods, art brokers and art warehouse keepers - Special feature: Here, the order is to be made if mainly "high-value goods" are traded. This is the case, for example, with cars but also watches, jewellery and other highly mobile and rather expensive goods.
(Source: §7 GWG, §2 GWG)
Money laundering reporting officers must be appointed at management level, but may often not be recruited directly from this level. In order to fulfil his duties, an money laundering reporting officer must be directly subordinate to the management. This is because the money laundering reporting officer and his deputies must be able to access all the information they need to perform their duties, which naturally includes sensitive business areas. At the same time, the management level of a company remains responsible for any violations of money laundering prevention measures.
Both the money laundering officer and his deputy must be granted special employee protection rights. "(...) because of the performance of their duties [they] must not suffer any disadvantage in their employment relationship" (§7 GWG para. 7). This is already limited in that money laundering reporting officers and their deputies are subject to special protection against dismissal, which also extends beyond employment as money laundering reporting officers or deputies.
A "gap audit" / AML audit of your money laundering compliance measures looks for gaps in your risk management. This involves taking the requirements of the Money Laundering Act and applying them to your system. For example, are the reporting requirements set out in the Money Laundering Act or the obligations to submit suspicious activity reports being complied with? Does your risk management work not only in theory but also in practice?
A gap audit should be carried out regularly in order to react adequately to internal and external changes in risk factors. A faulty or incomplete money laundering prevention system can lead to fines and penalties just as much as no money laundering prevention at all.
Yes. Kerberos can also conduct independent audits of your internal safeguards if we ourselves provide the money laundering reporting officer. The audit is carried out by independent organisational units. An audit of your internal security measures by Kerberos with the simultaneous appointment of an external money laundering reporting officer even makes sense. This makes it possible to implement possible improvements more quickly and cost-effectively.