The MLRO
The Money Laundering Reporting Officer receives internal reports of suspicious activity and is responsible for reporting to the authorities where appropriate. In inspections, a key focus is whether the MLRO can clearly explain how the firm identifies, assesses, and mitigates AML risk.
The MLCO
The Money Laundering Compliance Officer is responsible for the firm's overall AML compliance framework — that the policies, controls, and procedures are in place and working. The MLCO owns the framework the MLRO operates within.
What both need to evidence
- Approved, version-controlled AML policies mapped to their sources
- A current firm-wide risk assessment aligned to practice
- Ongoing, role-specific training with comprehension evidence
- Escalation rationale and decision records
- Approval trails and exportable evidence for SRA reviews
Showing it works in practice
The SRA tests whether the framework operates, not just exists. Evidence that staff understood training, that escalation decisions are recorded, and that policies match files is what demonstrates a framework working in practice.
Reglo helps firms keep this evidence organised and audit-ready — humans approve every change. AI drafts and organises; your compliance team decides.
This guide is general information for compliance teams, not legal or regulatory advice. Always refer to the SRA's current guidance and take your own professional advice where needed.