Job Description – Money Laundering Reporting Officer (MLRO)
Location: Hong Kong
Department: Compliance
Reporting to: Senior Management / Board of Directors
Position Level: Manager / Senior Manager
1. Key Responsibilities
- 1. Act as the central point of contact for receiving and assessing internal suspicious transaction disclosures and exception reports.
- 2. Ensure that employees promptly escape suspicious activities directly to the MLRO without undue delay.
- 3. Review and investigate suspicious activities and determine whether Suspicious Transaction Reports (STRs) should be submitted to the Joint Financial Intelligence Unit (JFIU).
- 4. Submit STRs to the JFIU promptly in accordance with applicable Hong Kong AML/CFT requirements.
- 5. Maintain proper records of internal disclosures, investigations, assessments and STR submissions.
- 6. Ensure confidentiality of suspicious transaction reports and provide guidance to staff on preventing tipping-off.
- 7. Liaise with the JFIU and relevant law enforcement authorities on AML/CFT matters.
- 8. Keep abreast of relevant AML/CFT regulatory developments and provide guidance on suspicious transaction reporting requirements.
2. Qualifications and Requirements
- 1. Bachelor's degree in Law, Finance, Accounting, Business Administration or a related discipline, or relevant professional qualifications.
- 2. At least 5 years of relevant experience in AML/CFT, regulatory compliance or financial crime risk management, preferably in a managerial or supervisory capacity.
- 3. Previous experience in Hong Kong TCSP, trust and corporate services, or financial institutions is highly preferred.
- 4. Strong knowledge of Hong Kong AML/CFT laws and regulations, particularly the Anti-Money Laundering and Counter-Terrorist Financing Ordinance (Cap. 615) and the Companies Registry's AML/CFT Guidelines for TCSP licensees.
- 5. Practical experience in CDD, EDD, customer risk assessment, suspicious transaction investigations and STR reporting.
- 6. Demonstrated ability to exercise independent judgment, manage compliance matters and communicate effectively with senior management and regulatory authorities.
- 7. Sufficient seniority, authority and AML/CFT expertise to effectively discharge the responsibilities of the MLRO.
- 8. Strong integrity, professionalism and ability to handle confidential information. The candidate should normally be based in Hong Kong.
3. Reporting Authority and Independence
- 1. The MLRO shall have sufficient seniority, authority, knowledge and independence to discharge the responsibilities effectively.
- 2. The MLRO shall have appropriate access to senior management and direct access to senior management where necessary.
- 3. The Company shall provide adequate resources, relevant information and access to customer and transaction records to enable the MLRO to perform the role effectively.
- 4. The MLRO should, as far as practicable, operate independently of business and operational functions.
- 5. An appropriate Alternate / Deputy MLRO arrangement shall be maintained to ensure continuity of responsibilities.