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Outsourcing MLRO


Outsourcing MLRO

Is your plan Outsourcing MLRO to Germany? With S+P Compliance Services you get a custom-fit solution for your company and your business model. We offer outsourcing solutions for the MLRO. For the establishment of an audit-proof risk management for money laundering prevention, we take on the following tasks:

  • Appointment as MLRO
  • As MLRO, we monitor compliance with the German Money Laundering Act (GwG) and other legal requirements, including the requirements of other company guidelines on money laundering prevention.
  • As MLRO, we advise and inform the company management with regard to existing obligations for money laundering prevention and are responsible for communicating with supervisory authorities.
  • We monitor selected processes on a random, risk-oriented basis and at appropriate intervals to ensure that they comply with the German MLA.
  • As MLRO, we perform our duties free of instructions and using the necessary expertise. We report directly to the company management.

Ensuring sufficient compliance for the prevention of money laundering + Outsourcing MLRO

In order to ensure sufficient compliance for the prevention of money laundering, it is mandatory to implement the following 16 compliance obligations:

  1. Implementation and monitoring of all regulations for the prevention of money laundering and terrorist financing

  2. Contact person for BaFin, FIU and law enforcement authorities

  3. Establishment of appropriate risk management including clear reporting obligations

  4. Preparation of an institution-specific risk analysis

  5. Developing and updating internal policies, appropriate business and customer-related safeguard systems

  6. Implementation of ongoing risk-oriented, in-process or at least timely monitoring, auditing and control measures

  7. Ongoing development of strategies and safeguards

  8. Operation and updating of appropriate data processing systems

  9. Investigation of unusual or doubtful circumstances

  10. Processing of suspicious cases including the submission of suspicious activity reports

  11. Deciding on the termination of the business relationship with the involvement of management

  12. Informing the management and the supervisory body: vis-à-vis the management in particular about deficits in the prevention measures and measures taken to remedy deficits, drawing up a report at least once a year on activities and the institution’s risk situation, if necessary within the framework of the risk analysis, as well as ad hoc reports if there are special reasons.

  13. The management board shall forward the report to the chairman of the supervisory body, whereby significant deviations from the assessments of the money laundering officer shall be specifically documented. The chairman of the supervisory body, for his part, has information rights directly vis-à-vis the money laundering officer.

  14. Conduct training and keep employees informed about new methods of money laundering and terrorist financing as well as new legal and supervisory requirements and the resulting rules of conduct.

  15. Advising and assisting employees and business units in complying with legal requirements for the prevention of money laundering and terrorist financing

  16. Involvement in the creation and amendment of relevant organisational and work instructions

Outsourcing MLRO

Anti Money Laundering Officer

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