Clifford Chance

A mixed report for money laundering officers

22 May 2012

Last week saw mixed fortunes for the individuals within financial institutions who act as Money Laundering Reporting Officers ("MLROs") and who oversee anti-money laundering ("AML") controls. The High Court has rejected a long running challenge by former customers to a bank's decisions to make Suspicious Activity Reports ("SARs"), in a decision that recognises the delicate balance that MLROs are required to strike between their own and their institutions' competing legal and commercial obligations.  On the other hand, the significant personal responsibilities of such officers has been highlighted by the first fine imposed on an individual to arise from the Financial Services Authority's thematic review into authorised firms' compliance with their AML obligations.

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