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Outsourcing MLRO for Investment Firms


Outsourcing MLRO for Investment firms

Are you looking for a MLRO for your Investment Firm? We offer outsourcing solutions for outsourcing MLRO for Investment firms. We take on the following tasks for the establishment of an audit-proof risk management for money laundering prevention:

  • 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 for Investment firms

In order to ensure sufficient compliance for the prevention of money laundering, the following 16 compliance obligations must be mandatorily implemented when outsourcing money laundering officers to capital management companies:

  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 for Investment firms

Proper business organisation

Securities institutions, groups of securities institutions, investment holding companies, mixed financial holding companies as well as parent companies of groups of securities institutions must, without prejudice to the obligations listed in §§ 4 to 6 of the Money Laundering Act as well as the organisational obligations contained in this Act, have an appropriate risk management system as well as internal security measures in place to prevent criminal acts that may lead to a threat to the assets of the securities institution.

Appropriate risk management

and to set up internal security measures. These serve to prevent money laundering, terrorist financing or other criminal acts that could endanger the assets of the institution.

Function of the MLRO

Within the meaning of Section 33 (5) of the Securities Institutions Act and the duties to prevent criminal acts within the meaning of paragraph 1 sentence 1 may also be performed by one office (central office) at the investment firm. The Federal Financial Supervisory Authority may, at the request of the company, permit another office within the institution to be responsible for preventing criminal acts, provided there is good cause for doing so.

MLRO Capital management companies

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