Company 1 with a single director and no other employees. Multiple clients. Work is sub-contracted to a team from company 2 which is owned by the same shareholder.
Logically, company 1 needs an AML policy and an MLRO - the staff are working on company 1's clients and should be able to report any concerns to its MLRO rather than their actual employer.
However, if there is only 1 director (who would have to be the MLRO) and no other employees, who could be the deputy MLRO?
I have asked the ICAEW and am waiting for a response, but thought I would ask members of the forum if they had any ideas.