MLRO and deputy?

MLRO and deputy?

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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.

Replies (2)

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By johngroganjga
29th Jul 2015 12:09

Who says a one person company / firm has to have a deputy MLRO?

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Replying to Tax Dragon:
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By nicstone
29th Jul 2015 12:18

I don't think it is required but...

If there is no deputy, what happens when the MLRO is unavailable and one of the team want to discuss making a report?  I can see that in a 1 person company, where that person does all the work, it is not necessary.  However, where there is a team of 6 people working on the company's clients, it feels wrong that they would be left without someone internal to report to.

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