Olivia is a director and money laundering reporting officer (MLRO) of NRO Bank, a small local bank based in a jurisdiction of your choice.

Olivia is a director and money laundering reporting officer (MLRO) of NRO Bank, a small local bank based in a jurisdiction of your choice. She is responsible for a number of areas of the Bank’s operations, including the Human Resources division and New Business Acquisition, as well as bearing the AML responsibilities.

Olivia has a strong personality and is trusted by the Bank’s board, who rely on her to get things done. She is rarely challenged by other members of the board or other staff members.

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The Bank has recently been the subject of a regulatory visit and the report that followed has been highly critical of both the board and the MLRO. Key criticisms included the following failings.

• • A failure on the part of the MLRO to process internal suspicious activity reports (SARs)/suspicious transaction reports (STRs) and externalise them to the Financial Intelligence Unit (FIU) (26 in total, with some as old as 18 months).

• • The MLRO deliberately misled the board into believing that money laundering was not a significant issue within the Bank. She deliberately failed to notify the board that internal SARs had been made.

• • The board of the Bank failed to meet regularly and did not monitor the internal AML reporting system and processes.

• • The MLRO was an extremely powerful individual and deemed unapproachable by members of staff.

• • The Bank prioritised business development over compliance.

• • From a corporate governance perspective, it was inappropriate for Olivia to control so many other areas of the Bank’s operations while also carrying out the MLRO role.

a) Under the local anti money laundering laws and regulations, have the MLRO and the Bank committed any criminal offences? Outline the key provisions of the law that may have been breached.

b) Indicate the risk consequences arising from the issues highlighted in the regulatory report.

c) What remedial action do you believe the Bank should take in order to remedy the issues highlighted?

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