The Line in the Sand: Senior Management Responsibility and Independence of the MLRO

Shaune Williamson

The purpose of this paper is to explore what it means for an AML Compliance Officer (MLRO) to act independently. In particular, where is the point of balance between the responsibility of senior management to ensure the effectiveness of a Firm’s AML/CFT Program, and the need for management to allow independence to the MLRO in performing the MLRO’s function?

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