[YOUR COMPANY NAME]

MLRO REPORT TEMPLATE

FREE VERSION

DOCUMENT AUTHOR: [Insert Author]

DOCUMENT OWNER: [Insert Owner]
STATUS: [Draft/Approved]
DATE CREATED: [Insert Date]
VERSION: [Insert Version]
LAST UPDATED: [Insert Date]
MLRO Report Template Version 1

SECURITY CLASSIFICATION: [High/Medium/Low]

Document Customisation
This page (to end of the ‘disclaimer’) provides template guidance and must be removed from the
finished version. For information on customising this template, please refer to the ‘Instructions’
supplied with your order.
It is important to work through the document and customise any areas to ensure that the finished
template accurately reflects what your organisation does and the controls that you have in place.
You should consider your regulatory and legal obligations and any standards or requirements that
apply to your industry or business type when customising the content.

Template Guidance
We have provided a generic template as a starting point for you to develop your own document in
this compliance area. You should review and customise the template sections thoroughly to ensure
that the finished version accurately reflects your organisations’ controls and responsibilities.
NOTE: This is a generic template for an internal MLRO report. The sections in this report are not
exhaustive and must be customised to suit your business type and obligations. FCA Handbook
module SYSC 6.3.7(2) advises that a firm with obligations under the Money Laundering Regulations
should provide appropriate information to its governing body and senior management, including a
report at least annually on the operation and effectiveness of the AML systems and controls. It is
your responsibility to ensure that this report covers all of the mandatory information applicable to
your organisation.

Referencing Other Policies

We sometimes reference other policies in a template where relevant (i.e. refer to Anti-Bribery &
Corruption Policy in conjunction with AML). Referenced documents are only included in your pack if
you have ordered them separately or you have purchased a Toolkit or Bundle that includes them.
Licence Terms
This is a free template to which Know Your Compliance Limited own the intellectual property rights.
Permission is granted to use this template within your organisation for the sole purpose it is
intended. The template cannot be used, sold or transferred elsewhere without written permission
from Know Your Compliance Limited.

Disclaimer
Know Your Compliance Limited has created this template for you to use in developing and
implementing your compliance program requirements. Whilst every reasonable care is taken to
ensure that the content is relevant, compliant and up to date; it is your responsibility to ensure that
the finished policy complies with any regulatory and/or legal requirements and standards.
It is important that you customise the content to suit your industry needs and business type. Know
Your Compliance Limited makes no claims or guarantees about the compliance or adequacy of the
content in this template and accepts no responsibility or liability for any loss, damage or expense

[Insert Date] Page 2 of 12

MLRO Report Template Version 1

incurred as a result of reliance on the content contained herein. If you are unsure of your regulatory
or legal obligations, you should obtain legal or professional advice before publishing, using or relying
upon your finished policy.

Purchase Compliance Templates

Know Your Compliance Limited provide hundreds of regulatory documents to over 6000
organisations. If you require further templates to support your Anti Money Laundering or FCA
compliance, please use the below links to visit our website. We also specialise in GDPR and
Information Security compliance templates.

For Anti Money Laundering Templates, visit our AML Products page for AML Policy
Templates, AML Checklist, AML Risk Assessment Template, SAR Procedures and our 30+ AML
Document Toolkit.
For FCA Templates, visit our FCA Products for FCA Policy Templates, FCA Checklists, FCA
Compliance Manual, SMCR Toolkit, CASS Manual & Resolution Packs, TCF, Vulnerable
Customers and more.
For GDPR Templates, visit our GDPR Products for GDPR Policy Templates, 80+ Template
GDPR Toolkit, Data Protection Impact Assessment, GDPR Gap Analysis Checklist, PECR
Templates and more.

[Insert Date] Page 3 of 12

MLRO Report Template Version 1

Revision History

VERSION REVISION SECTION REASON FOR REVISION DESCRIPTION OF REVISION

DATE REVISED

[Insert Date] Page 4 of 12

MLRO Report Template Version 1

MLRO Annual Report Template

1. COMPANY DETAILS
MLRO Name:

Date Report Compiled:

Reporting Period:

Date of Submission to Senior

Management:

Summary of Duties Performed by

Appointed MLRO:

Nominated Deputy in MLRO’s

Absence:

Other Roles Held by MLRO (e.g.

Nominated Officer under Money
Laundering Regulations, Proceeds of
Crime Act and Terrorism Act etc)

2. SYSTEMS & CONTROLS

a. Are the AML/CFT policy and procedure documents up to date? YES/NO
b. Are they adequate to meet the firm’s needs & mitigate financial crime risks? YES/NO
Describe how the adequacy of the AML documents was assessed e.g. methods, tools etc

c. Are they effective in meeting the regulatory & legal rules & requirements? YES/NO
Describe how the effectiveness of the AML documents was assessed e.g. methods, tools
etc

d.

Detail any areas where the firm’s AML policies, procedures, systems and/or controls
should be improved, and proposals for making appropriate improvements: -

[Insert Date] Page 5 of 12

MLRO Report Template Version 1

e. Do the existing controls and measures ensure that your firm can identify, assess, monitor
and manage money laundering risk? YES/NO

f. Are client identification procedures effective and adequate? YES/NO

g. Have due diligence checks been completed & retained for all new clients? YES/NO

h. Are your Risk Management policies and procedures up to date? YES/NO

i. Are they adequate to meet the firm’s needs & mitigate financial crime risks? YES/NO
Describe how was the adequacy of the Risk Management documents was assessed

j. Are they effective in meeting the regulatory & legal rules & requirements? YES/NO
Describe how the effectiveness of the Risk Management documents was assessed

Detail any areas where the firm’s Risk Management policies, procedures, systems and/or
controls could/should be improved, and proposals for making appropriate improvements: -

3. BREACHES & REPORTS

a. How Many Internal Suspicious Activity Reports (SAR’s) Were Completed? ____

b. Number of SAR’s Passed to the FCA/NCA? ____

Provide a summary of the SAR’s passed to the regulator(s)

[Insert Date] Page 6 of 12

MLRO Report Template Version 1

c. Number of SAR’s NOT Passed to the FCA/NCA? ____

Provide the reason why any SAR’s were not referred to the regulator(s)

d. Were there any breaches of internal AML/CFT policies and/or procedures? YES/NO
Provide details of any breaches and mitigating actions:

e. Were there any breaches of FCA regulations with regards to AML/CFT? YES/NO
Provide details of any breaches and mitigating actions:

f. Were there any breaches of regulations/laws regarding AML/CFT YES/NO

Provide details of any breaches and mitigating actions:

Outline the method used to identify suspicious transactions and/or activities: -

Describe arrangements for regular reporting, indicating frequency and those individuals
within the firms and regulatory bodies to whom reports are made: -

[Insert Date] Page 7 of 12

MLRO Report Template Version 1

Describe the scope and coverage of regular reports: -

4. TRAINING & ASSESSMENTS

a. Has appropriate and effective Financial Crime and AML training been provided to all
employees and associated personnel? YES/NO

b. Have all training materials been reviewed for compliance with current laws, regulations and
legislation? YES/NO

c. Are employees asked for feedback on the training content and delivery? YES/NO

d. Are assessment papers used to test AML knowledge and understanding? YES/NO

e. What was the date of the last content update/review for training materials? MM/YY

f. Have all staff received the training within the past 6 months? YES/NO
If any employee has not received the training, please provide details and reasons:

Please provide a summary of the AML/CFT training and assessment content: -

Detail any areas where the firm’s AML/CFT training program should be improved, and
proposals for making appropriate improvements: -

[Insert Date] Page 8 of 12

MLRO Report Template Version 1

Summarise the methods of training and quality checks performed for awareness and
training with regards to AML/CFT/Financial Crime: -

Summarise the training, courses and materials used to ensure that the MLRO and any
nominated deputy are up to date and compliant with AML/CFT/Financial Crime rules,
regulations and laws: -

5. DUE DILIGENCE & HIGH-RISK CLIENTS

a. Is a due diligence checklist and questionnaire used for all new customers? YES/NO

b. Are adequate/effective background checks performed on all new customers? YES/NO

Provide details of the background checks performed and any external systems/providers
used

c. Are adequate/effective background checks performed for all new employees? YES/NO

d. Number of current PEP customers? ____

e. Number of non-UK based customers? ____

f. Number of current customers categorised as ‘other high-risk’? ____

Provide further details of the types of customer defined as ‘other high-risk’

[Insert Date] Page 9 of 12

MLRO Report Template Version 1

Describe the firm's new product/service approval process (if applicable): -

Detail any business relationships where due diligence checks were not performed and
provide reasons why (if applicable): -

6. AUDITS & MONITORING

a. Are adequate/effective monitoring and audit procedures and controls in place? YES/NO
Provide details of the outcome of any monitoring or audit plans carried out

b. Based on the audit and monitoring outcomes, are the AML/CFT controls and measures
deemed to be comprehensive and proportionate? YES/NO

c. Are transaction monitoring processes adequate and effective? YES/NO

d. Were ‘Source of Funds’ checks carried out? YES/NO/NA

7. SUMMARY

Summarise any regulatory/legislative changes during the reporting period and their
impact on the firm's systems, controls and measures: -

Summarise any impending and/or future regulatory/legislative changes that could

[Insert Date] Page 10 of 12

MLRO Report Template Version 1

impact the firm's systems, controls and measures and suggestions for actions and/or
mitigations: -

Indicate changes in activity and elements of the business that have had implications for
money laundering controls: -

Provide a summary of any additions, improvements and/or suggestions that are to be

presented to the Senior Management from the reporting period: -

Describe in order of priority, areas for remedial/preventative action, the action deemed
necessary, and an expected timeframe for completion: -

TO BE COMPLETED BY THE MLRO

Have all questions been completed? YES/NO

Have any associated documents been attached? YES/NO

Signed: _______________________

Print Name: _______________________

Date: _______________________

TO BE COMPLETED BY SENIOR MANAGEMENT REPRESENTATIVE

[Insert Date] Page 11 of 12

MLRO Report Template Version 1

Have all questions been completed? YES/NO

Has the content contained in the report been reviewed and considered? YES/NO
Has approval of any improvement actions been given? YES/NO

Signed: _______________________
Print Name: _______________________
Date: _______________________

[Insert Date] Page 12 of 12