Money Laundering Reporting Officer (MLRO) Essentials

High-level strategy and operational decision-making:

The role of an MLRO is no longer just about compliance; it's about managing high-stakes legal and personal risk. As the UK enters a new era of enforcement under the Economic Crime and Corporate Transparency Act, this workshop provides the essential "health check" for senior professionals.

Learning outcomes:

This is a hands-on session for those responsible for signing off on Suspicious Activity Report (SARs) and managing firm-wide risk. We move beyond the basics to focus on:

Benchmarking your approach: Compare your firm’s risk appetite and SARs processes with other industry leaders.
Reporting standards: Understand exactly how to structure your reports, so they provide the specific insights law enforcement needs to take action.
Managing risk: Learn how to document your decision-making process to protect both your firm and yourself from regulatory scrutiny.

Inside the agenda:

The session is built around four practical modules:

From monitoring to suspicion: How Customer Due Diligence (CDD) and ongoing monitoring help you identify "knowledge or suspicion" under the Proceeds of Crime Act (POCA).
Mastering the narrative: What makes an effective Suspicious Activity Report (SAR)? Learn how to write with clarity and relevance while clearly explaining your suspicion.
Managing the consent process: Practical strategies for requesting a Defence Against Money Laundering (DAML) while ensuring you do not alert the client or prejudice an ongoing investigation.
Information sharing and reform: How recent legal changes are making it easier for firms and law enforcement to share intelligence and collaborate.

Meet your trainer: Ruth Paley

Ruth Paley is a Partner at Michelman & Robinson and a leading authority on corporate crime, financial regulation, and investigations. Consistently recognised by the Legal 500 as a “powerhouse performer,” she brings a wealth of practical experience to the workshop:

Strategic practitioner: Ruth works alongside Boards and Executive Committees (ExCos) to navigate large-scale remediations and complex enforcement strategies.
The "inside" track: She has extensive experience leading internal investigations and representing global financial institutions facing scrutiny from the Serious Fraud Office (SFO) and the City of London Police.
Solutions-focused: Ruth specialises in protecting both the firm and its senior executives from regulatory risk, providing practical ways to manage "real-world" criminal activity and third-party exposure.
"Ruth’s approach goes beyond the letter of the law; she provides a masterclass in risk mitigation, showing you how to apply the UK Money Laundering Regulations to protect your firm’s best interests when facing regulatory pressure."

Course details

Level: Advanced / Refresher
Audience: MLROs, Deputy MLROs, and SMF17 holders
Format: Interactive in-person workshop (designed for interactive discussion and peer networking).

Interested in taking any of our workshops in-house

Whether you are seeking to upskill your team, enhance productivity or foster a culture of continuous learning, we can deliver customised training programmes designed to meet your specific needs. If you have an enquiry, you can complete the in-house form and our training team will be in touch with next steps.

IN-HOUSE TRAINING

Area of expertise:

Economic crime

Quick recap of the UK AML framework

This opening segment provides a structured refresher of the core criminal AML provisions under UK law, setting the foundation for the SARs-focused discussions that follow. It will cover:

The principal money laundering offences under the Proceeds of Crime Act 2002 (POCA), including the distinctions between the primary laundering offences and the regulated sector offences.
The scope and mechanics of the failure to disclose offence, including who is caught, what constitutes “knowledge or suspicion”, and the relevance of the appropriate disclosure defence.
The offences of tipping off and prejudicing an investigation, including how these risks arise in day-to-day client communications and internal escalation processes.
Practical examples illustrating how these offences are most commonly engaged in professional services and financial services contexts.
The focus will be on clarifying grey areas that frequently cause uncertainty in practice rather than re-stating black-letter law.

Interactivity between these provisions and the UK Money Laundering Regulations

This section explores how the criminal law framework interacts with the preventive regime under the Money Laundering Regulations (MLRs), and where firms often misunderstand the relationship between the two. Topics include:

How the MLRs’ risk-based requirements (CDD, ongoing monitoring, record-keeping) feed into the formation of knowledge or suspicion under POCA.
Common misconceptions around when regulatory non-compliance does (and does not) translate into criminal exposure.
The practical role of MLROs and nominated officers at the intersection of the regulatory and criminal regimes.
Regulatory expectations on escalation, internal SARs and governance, and how these align with statutory disclosure obligations.

NCA SARs reporting – what can we learn from published statistics on SARs?

Using the NCA’s annual SARs reports and related publications, this segment examines what the available data tells us about how the SARs regime operates in practice. It will cover:

Key trends in SARs volumes, reporter sectors and reporting behaviour.
Insights into SAR quality, including recurring issues highlighted by the NCA.
What the statistics reveal about the operational use of SARs by law enforcement.
Limitations of the published data and what firms should (and should not) infer from it.
The aim is to ground SARs decision-making in evidence rather than assumptions.

SARs reporting – what does good look like?

This section focuses on regulatory and law enforcement expectations around high-quality SARs. It will address:

The core characteristics of an effective SAR, including clarity, relevance, and the articulation of suspicion.
The importance of narrative structure and the distinction between facts, context and analysis.
Common hallmarks of SARs that are genuinely useful to law enforcement.
Practical tips for improving internal processes to support better-quality reporting.
Examples will be used to illustrate how small drafting choices can materially affect the value of a SAR.

SARs reporting – where can it go wrong?

This extended, practical session examines the most common failure points in SARs reporting and related processes, drawing on enforcement action, supervisory findings and real-world experience. Topics include:

Over-reporting versus under-reporting, and the risks associated with both.
Poorly articulated suspicion, defensive SARs and “data dumps”.
Timing issues, including late reporting and delays caused by internal governance.
Tipping off risks arising from client engagement, internal communications and remediation activity.
Inadequate documentation of decision-making and rationale.
Sharing “war stories” from practice, including NCA enforcement scenarios, and the practical lessons that follow.
This session will be highly practical and scenario-driven, encouraging participants to test their judgement against realistic fact patterns.

Significant AML developments which have flown under the radar

The closing segment highlights important legal and regulatory developments that have not always received sustained attention but have meaningful implications for MLROs and their firms. These include:

Recent and forthcoming changes to information-sharing provisions and how they may affect collaboration between firms and law enforcement.
Developments in the attribution of criminal liability to senior managers and implications for governance and oversight.
Reforms and proposed reforms to SARs systems and information-sharing mechanisms, including what firms should be doing now to prepare.
Emerging themes in supervisory and enforcement approaches that may shape future expectations.
The session will conclude with a brief discussion of practical takeaways and areas where firms may wish to reassess existing policies and controls.

Ruth Paley

Partner, Michelman Robinson

Ruth Paley is a leading authority on corporate crime, financial regulation, and investigations, with particular expertise in anti-money laundering (AM...

Ruth Paley is a leading authority on corporate crime, financial regulation, and investigations, with particular expertise in anti-money laundering (AML) and enforcement strategy. Known for her command of the UK Money Laundering Regulations, Ruth is consistently recognised as a top practitioner in her field, “a powerhouse performer in global corporate investigations,” and “one of the leading names in anti-money laundering work in London, with a depth of knowledge few in the City have” (Legal 500).

She acts for global corporates, financial institutions, and senior executives facing exposure to criminal and regulatory risk. Ruth frequently leads internal investigations, large-scale remediations, and regulatory inquiries, working side-by-side with Boards and ExCos to advise on enforcement strategy and risk mitigation. She is often called upon to support firms grappling with criminal activity on the part of employees and third parties, using a solutions-focused approach to protect her clients’ best interests. Ruth also represents individuals under investigation by the SFO, the City of London Police, and other enforcement authorities.