# MLRO (Money Laundering Reporting Officer)

**MLRO (Money Laundering Reporting Officer) is the common industry name for the person responsible for a firm's anti-money-laundering controls and for reporting suspicions to the financial intelligence unit (FIU).** EU law does not use the term: the AMLR calls this role the "compliance officer", alongside a "compliance manager" on the management body. In Belgium, the National Bank of Belgium (NBB) calls it the AMLCO.

*Also called:* AML compliance officer, AMLCO (Belgium).

## Why it matters for PSPs and EMIs

In a payment or e-money institution, the MLRO owns the questions that matter most in an onboarding file: is this reportable, can we contact the customer, can we proceed? The AMLR also makes the role more formal — with protection against retaliation, a direct line to the management body and a duty to notify the supervisor if the officer is removed.

## What the law says

- **Compliance manager.** AMLR Art. 11(1): a member of the management body in its management function, responsible for ensuring compliance with the AMLR.
- **Compliance officer.** AMLR Art. 11(2): appointed by the management body with sufficiently high hierarchical standing; responsible for AML/CFT policies, procedures and controls day to day, including targeted financial sanctions; the contact point for competent authorities; and responsible for reporting suspicious transactions to the FIU (Art. 69(6)).
- **Independence and resources.** AMLR Art. 11(3) to (5): adequate resources including technology; protection against retaliation; decisions not unduly influenced by commercial interests; direct reporting to the management body.
- **Other duties.** AMLR Art. 10(2): the compliance officer draws up the business-wide risk assessment. Art. 11(6): an annual report on internal policies and controls. Art. 11(7): where justified, the two roles may be held by the same person.
- **Current guidance.** EBA Guidelines EBA/GL/2022/05 on the role and responsibilities of the AML/CFT compliance officer.
- **Belgium (current law).** Law of 18 September 2017, Art. 9 §1 (the person responsible at the highest level) and Art. 9 §2 (the persons in charge of implementing AML policies and analysing atypical transactions — the AMLCO).

## How ProofVolt handles it

In ProofVolt, when a case carries a criminal, enforcement, sanctions or asset-freeze finding, customer contact waits for the MLRO's signed reportability assessment, and no officer can override that. ProofVolt supports the MLRO in preparing the suspicious transaction report — the draft, the reportability assessment signed by someone other than the person who raised the concern, and a goAML XML export — which the MLRO then submits through the FIU's own channel. Every source, step and decision is kept in an append-only trail.

## Related

- [Suspicious activity report (SAR/STR)](/glossary/suspicious-activity-report/)
- [Tipping-off](/glossary/tipping-off/)
- [Four-eyes principle](/glossary/four-eyes-principle/)

Canonical: https://proofvolt.eu/glossary/mlro/