As many of us in the industry are aware, the Financial system is governed by various bodies and regulators. In the United Kingdom, one of the most prominent tools in the Anti-Money Laundering, (AML) space, is the Financial Conduct Authority (FCA) handbook. The handbook guides Firms across a range of topics, from Financial Reporting Requirements to Market Abuse Regulation (MAR) and Market Conduct. One of the most important parts of this handbook is the guidance around the requirement for Firms to have a Money Laundering Reporting Officer, (MLROs) or otherwise known as a Nominated Officer under the Proceeds of Crime Act 2002 (POCA).
This requirement is widely recognised within many Financial Institutions, (FIs) however in the emerging market of Crypto assets, many start-ups are ill-equipped to fulfil such an obligation.
As per the FCA handbook:
‘The job of the MLRO is to act as the focal point within the relevant firm for the oversight of all activity relating to anti-money laundering. He/she needs to be senior, to be free to act on his/her own authority and to be informed of any relevant knowledge or suspicion in the relevant firm. '