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Key takeaways
An outsourced MLRO is risky for most small firms. The Money Laundering Regulations 2017 require a nominated officer to receive internal reports and decide whether to report suspicions to the National Crime Agency, and supervisors generally expect that person to be inside the business with enough seniority and access. You can buy in training, reviews, policies and admin support.
- Keep the nominated officer role and reporting decisions inside.
- Buy in: training, policy drafting, file reviews and audits.
- Outsource admin such as ID checks, under your control.
- Check your supervisor's guidance: FCA, HMRC or professional body.
Want AML admin support while you keep the decisions? Message us on WhatsApp.
Chat on WhatsApp →Why should the MLRO role stay inside?
Because the role depends on knowing the firm's clients, staff and transactions, receiving reports quickly and making confidential judgements about suspicion. An outsider may lack the access and the authority. Supervisors also expect a senior person to be responsible for compliance with the regulations where appropriate to the firm's size.
What anti-money laundering work can be outsourced?
Specialist support and admin, provided the firm stays in control.
- Writing and updating policies and risk assessments.
- Staff training.
- Independent file reviews and audits.
- Collecting ID documents and running checks.
- Keeping client due diligence records.
Who is responsible if checks are wrong?
The regulated business. Under the regulations, a firm can rely on certain third parties for customer due diligence in limited circumstances, but it remains liable for any failure. Where an outsourced team does checks, set clear instructions and sample the results.
What does this look like in practice?
A pattern we see: small practices spend partners' time chasing ID documents. Moving the chasing and record keeping to an outsourced team, while the MLRO reviews risk and decides on suspicion, frees time without weakening control.
MLRO checklist
- Appoint a nominated officer inside the firm.
- Write a firm-wide risk assessment.
- Train staff on reporting.
- Outsource ID collection under clear instructions.
- Commission an independent review yearly.
Next step
Check your supervisor's guidance on the nominated officer and write down who holds the role, who deputises and what support you buy in.
Message us on WhatsApp, or book a 30-minute consultation.
Chat on WhatsApp →Sources and further reading
- The Money Laundering, Terrorist Financing and Transfer of Funds Regulations 2017 · legislation.gov.uk
- Money Laundering Regulations: your responsibilities · HM Revenue & Customs
Frequently asked questions
Can an MLRO be outsourced?
Supervisors generally expect the nominated officer to be a senior person within the business who knows its clients and has access to its information. Firms can buy in training, policy drafting, file reviews and admin support. Check your own supervisor's guidance before deciding.
What does a nominated officer do?
Under the Money Laundering Regulations 2017, the nominated officer receives internal reports of suspected money laundering, decides whether there are grounds to report, and makes suspicious activity reports to the National Crime Agency where required.
Can client ID checks be outsourced?
Collecting documents and running checks can be outsourced to a provider working on your instructions, but the regulated business remains responsible for customer due diligence. Set clear rules, keep records and sample the provider's work regularly.
Written by
Global Bridge Labs (GBL) is a UK–Sri Lanka partner for social media, websites and BPO. Everything here comes from client delivery, not theory.
