The role and responsibilities of the Board and senior management, AML/CFT compliance team, and Money Laundering reporting officer MLRO.
The Board and senior management
The Board of financial firms is responsible for the effective management of the institution. They are best placed to evaluate and understand all possible risks facing the bank, including ML/TF. The Board takes ownership and responsibility for the business’ risk assessment and makes sure they remain relevant and up-to-date (Kalinina, 2019). The Board also ensures the review of compliance policy accounts for the complexity, nature, and size of the business, including the recognized risks during risk assessment. On the other hand, senior management is an employee of officer equipped with knowledge about the institution’s exposure to money laundering and terrorist financing risk and has adequate priority to decide on risk exposure factors affecting the firm. The senior management need not be a board member at all times (Kalinina, 2019). The Board of Directors interface with the compliance team and the MLRO as the Board document controls such as policies and procedures and the bank’s systems and allocate responsibilities for ML/FT, but particularly to the compliance team and MLRO.