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Outsourcing MLRO + Compliance Officer

HIT THE GROUND RUNNING IN GERMANY – OUTSOURCING MLRO + COMPLIANCE OFFICER to Germany

Outsourcing MLRO

We offer competitive outsourcing packages for companies, asset managers and banks seeking outsourcing solutions in Germany. In Germany it is a requirement by law to have one MLRO (Money Laundering Reporting Officer) and one deputy MLRO. Our target is to establish for you a tailored audit-proof risk management for the prevention of risk management and CFT. Our outsourcing MLRO arrangements include the following:

  • Appointment as Money Laundering Reporting Officer (and Deputy MLRO) in Germany, if required
  • In this function we monitor your business in accordance to the German MLA (and guidelines to the German MLA) as well as other legal requirements, as applicable.
  • Advise and inform the management on existing obligations for the prevention of money laundering and TF
  • Assume responsibility to communicate with supervisory authorities.
  • Selected processes (as agreed with you) are monitored on a random basis, risk-oriented and in agreed frequencies for your compliance department.
  • As specialists with existing UK mandates, we can hit the ground running and only require your company specific information. As set out in the law, we report directly to the management.

Ensuring the required compliance for the prevention of money laundering + Outsourcing MLRO + Compliance Officer in Germany

To ensure the required compliance systems and processes are in place for the prevention of money laundering and CFT we have summarised for you the 16 legal obligations that need to be implemented within a MLRO outsourcing solution:

  1. Implementation and supervision of all regulations for the prevention of money laundering and terrorist financing (AML/CFT)

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

  3. Establish adequate risk management systems and processes including clear reporting requirements

  4. Tailored company specific risk assessment

  5. Development and updating of internal principles, appropriate business and customer-related security systems

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

  7. Continuous development of strategies and safeguards

  8. Operation and updating of adequate data processing systems

  9. Investigation of unusual or doubtful facts

  10. Handling of suspicious cases including the submission of suspicious transaction reports

  11. Decision about the termination of the business relationship with the involvement of the management

  12. Information to management and the supervisory body: Measures taken in particular concerning the deficits of the prevention measures and to remedy deficits, preparation of an at least annual report on activities and the risk situation of the company, if necessary, in the context of the risk analysis as well as ad hoc reports in the presence of special causes.

  13. The Board shall forward the report to the Chairman of the Board of Supervisors, with reference to any material deviations from the assessments made by the Money Laundering Reporting Officer. For its part, the chairman of the supervisory body has rights of access directly to the Money Laundering Reporting Officer.

  14. Providing training and ongoing information to employees about new methods of money laundering and terrorist financing as well as new legal and regulatory requirements.

  15. Advising and supporting employees and businesses in complying with anti-money laundering and terrorist financing legislation (AML/CFT).

  16. Advise on the improvement and adjustment on applicable organisational and clear task definitions and instructions.

    Investment firms

    Investment firms as well as branches located in Germany and branches of investment firms domiciled in Germany.

    FinTechs

    FinTechs pursuant to the German Banking Act (Kreditwesengesetz), and branches located in Germany and branches of credit institutions with their registered office in Germany.

    Payment Service Provider

    Payment institutions and electronic money firms pursuant to the Payment Services Supervision Act (Zahlungsdiensteaufsichtsgesetz) and branches located in Germany and branches of comparable institutions located in Germany.

    Capital Management Firms

    Capital management firms pursuant to the Capital Investment Act (Kapitalanlagegesetzbuch), branches of EU management firms and foreign AIF management firms located in Germany.

    Crypto Wallet Provider

    Custody, the administration and the safeguarding of crypto securities or private cryptographic keys used to hold, store or dispose of crypto securities for others, as well as the safeguarding of private cryptographic keys.

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