The MLRO - Duties & Responsibilities

The role of the Money Laundering Reporting Officer (MLRO) is crucial in ensuring that Subject Persons remain fully compliant with their financial crime compliance obligations and that they can immediately respond to the risks associated with money laundering and the funding of terrorism.

Given this critical role, MLROs are under increasing pressure to retain, maintain and enhance their skills and knowledge, whilst at the same time managing risks according to an adequately designed risk-based approach. This is highlighted further by the personal punitive measures that have been incorporated in the Prevention of Money Laundering & Funding of Terrorism Regulations (PMLFTR).

Over the two sessions participants will be offered practical advice and guidance on the duties and responsibilities of the MLRO, what is generally expected by the Regulatory Authorities, and how those responsibilities can be fulfilled. As such, it will provide:

• An explanation of what is expected of the MLRO;
• Practical ways to comply with the salient legislative provisions and meet regulatory expectations;
• Guidance on how to deal with Suspicious Transaction Reports (STRs) and conduct an internal analysis;
• The necessary knowledge for assessing the adequacy and effectiveness of an AML/CTF programme;
• An understanding of the challenges faced in executing the role; and
• An appreciation of the key characteristics of a MLRO, and how they can ensure effectiveness.

The presentations will also outline the salient regulatory framework, provide details relating to the appointment and resignation of the MLRO and delineate key needs and requirements.

The salient points raised by the Regulatory Authorities in the following two documents will also be incorporated into the sessions:

• “Common Issues Related to the Money Laundering Reporting Officer” (FIAU, April 2022); and
• “A Guidance for Money Laundering Reporting Officers in the Financial Services Sector” (MFSA, March 2024).

The Speaker

Antonio Ghirlando is a seasoned compliance specialist with a specific focus on financial crime compliance, including the prevention of money laundering, countering the funding of terrorism, combatting proliferation finance, sanctions, anti-bribery & corruption, and fraud. He is also well versed in other regulatory compliance obligations.

Antonio is actively involved in the provision of real-time operational support, specialist advice, intuitive guidance and training to several businesses seeking to ensure ongoing compliance with their regulatory obligations. He also assists Money Laundering Reporting Officers (MLROs) and Compliance Officers with their day-to-day tasks and oversight.

During his career he has worked with various licensed entities in both the financial and non-financial sectors, having served as the Head of Compliance, Head of Financial Crime Compliance, Money Laundering Reporting Officer (MLRO) and Data Protection Officer (DPO). He also headed the Compliance and Legal & International Sections of the Financial Intelligence Analysis Unit (FIAU) and served as the Secretary General of the Malta Bankers’ Association (MBA).

Antonio has been involved in several local and international committees, and has also presented numerous papers at various workshops, seminars, conferences and training events. Antonio is a graduate of the University of the Witwatersrand in Johannesburg, South Africa.