Category: Compliance & AML · Reviewed by Matt Bartlett, Director · Founder · Last reviewed June 2026
The senior individual in a regulated firm responsible for receiving internal disclosures of suspicion, deciding whether to submit a SAR to the National Crime Agency, and overseeing the firm’s AML / CFT systems and controls.
The Money Laundering Reporting Officer (MLRO) is the nominated officer required by both the Proceeds of Crime Act 2002 and the Money Laundering Regulations 2017. The MLRO acts as the central point for internal AML reporting, makes the decision on external SAR submission, and holds the SMF17 senior management function under the SM&CR.
Proceeds of Crime Act 2002, section 331 (failure to disclose — nominated officers). Money Laundering Regulations 2017, regulation 21 (nominated officer). FCA Handbook, SUP 10C.6A (SMF17). SYSC 6.3 (financial crime — systems and controls).
The MLRO receives internal disclosures from staff; investigates them; documents decisions; files SARs where the threshold of suspicion is met; oversees AML training; chairs or reports to the firm’s financial crime committee (where relevant); approves the firm-wide risk assessment under regulation 18; reports to the board at least annually on the AML control framework; engages with the FCA on financial crime supervision; and engages with law enforcement and the NCA on SARs and related inquiries.
In smaller firms (including most insurance brokers) the MLRO function is held by a director — typically combined with SMF3 (Executive Director) and / or SMF16 (Compliance Oversight). The MLRO must have sufficient seniority, independence and resources. The role is personal — decisions are made in the MLRO’s name.
At Apex, Matt Bartlett holds the SMF17 MLRO function. The MLRO process documents include the SAR decision register, the annual MLRO report to the board, the firm-wide risk assessment review log, and the staff training records.
Proceeds of Crime Act 2002, section 331. Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (S.I. 2017/692), regulation 21. FCA Handbook, SUP 10C.6A, SYSC 6.3. JMLSG Guidance Part I, chapter 3.
By Matt Bartlett, Director, on 2026-06-11.
This entry is part of the Apex Insurance Wiki. Last reviewed by Matt Bartlett on 2026-06-11. Apex Insurance Brokers Limited, FCA FRN 724952, Companies House 07014570. Not regulated advice — consult your broker on your specific position.
Apex Insurance Brokers serves UK professional services firms and commercial businesses. Call 0117 325 0027, email hello@apexinsurancebrokers.co.uk, or request a quotation.
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