089 45242970101 contact@sp-partners.de

Outsourcing MLRO

We offer outsourcing solutions for the Money Laundering Reporting Officer. For the establishment of a audit-proof risk management for money laundering prevention, we assume the following tasks:

  • Appointment as Money Laundering Reporting Officer
  • As a money laundering officer, we monitor adherence to the German MLA and other legal requirements, including the requirements of other guidelines on money laundering prevention.
  • As a money laundering officer, we advise and inform the management on existing obligations for money laundering prevention and are responsible for communication with supervisory authorities.
  • Selected processes are monitored on a random basis, risk-oriented and at appropriate intervals for their  compliance.
  • As a Money Laundering Reporting Officer we take over our tasks without instructions and using the necessary specialist knowledge. We report directly to the management.

You wish a free quote for your removal of the MLRO – Money Laundering Reporting Officer. We are happy to help. Send your request directly to the S&P Money Laundering Prevention Compliance Team, Email: a.schulz@sp-partners.de

Outsourcing MLRO

S&P Team Money Laundering Prevention – Outsourcing MLRO

The S&P Money Laundering Prevention Team offers a representation-safe outsourcing of the Money Laundering Reporting Officer.

Achim Schulz has been advising medium-sized companies and banks for 22 years. His areas of expertise include CRR institutes, acquirers, fintech, capital management companies, leasing and factoring companies and medium-sized companies.

He advises companies on the implementation of risk management and compliance systems.

Alexander Schneider has been working for banks, financial service providers, insurance companies and medium-sized companies for more than 20 years.

As a compliance and money laundering officer, Mr. Schneider advises companies on the implementation of money laundering compliance standards.

Lawyer Alexander Suck is an experienced expert with a focus on corporate and criminal law. Together with his legal team, he advises medium-sized companies on the implementation of legal obligations for money laundering prevention. He develops risk mitigation strategies for compliance and Money Laundering Reporting Officers.

Miriam Boglino is a legal advisor to fund companies in London. She advises medium-sized companies on the development of European compliance management systems.

Nesra Kazan is the money laundering and data protection officer in the S&P team responsible for the outsourcing of outsourcing solutions. She advises companies on the implementation of an audit-proof money laundering prevention system.

Ensuring sufficient compliance for money laundering prevention

To ensure sufficient compliance for money laundering prevention, the following 16 compliance obligations must be implemented:

  1. Implementation and supervision of all regulations for the prevention of money laundering and terrorist financing (AML/CFT)
  2. Contact for BaFin, FIU and law enforcement agencies
  3. Establish adequate risk management including clear reporting requirements
  4. Creation of an institute-specific risk assessment
  5. Development and updating of internal principles, appropriate business and customer-related security systems
  6. Implementation of ongoing risk-oriented, process-accompanying or at least timely monitoring, inspection and control measures
  7. Continuous development of strategies and safeguards
  8. Operation and updating of adequate data processing systems
  9. Investigation of unusual or doubtful facts
  10. Handling of suspicious cases including the submission of suspicious transaction reports
  11. Decision about the termination of the business relationship with the involvement of the management
  12. Information to management and the supervisory body: Measures taken in particular concerning the deficits of the prevention measures and to remedy deficits, preparation of an at least annual report on activities and the risk situation of the institute, if necessary in the context of the risk analysis as well as ad hoc reports in the presence of special causes ,
  13. The Board shall forward the report to the Chairman of the Board of Supervisors, with particular reference to any material deviations from the assessments made by the Money Laundering Reporting Officer. For its part, the chairman of the supervisory body has rights of access directly to the Money Laundering Reporting Officer.
  14. Providing training and ongoing information to employees about new methods of money laundering and terrorist financing as well as new legal and regulatory requirements and the ensuing rules on behavior.
  15. Advising and supporting employees and businesses in complying with anti-money laundering and terrorist financing legislation (AML/CFT).
  16. Involvement in the creation and modification of relevant organizational and work instructions.

Even non-financial companies need a money laundering prevention system

The German Money Laundering Act is aimed not only at companies in the financial sector, such as banks or corporations, but also at companies outside the financial sector.

Among other things, the Money Laundering Act applies to the following non-financial companies:

  • Goods traders (any person who sells commercial goods, regardless of in whose name or on whose behalf it trades),
  • Legal service providers (non-licensed legal assistants and registered persons according to § 10 of the Legal Services Act, if they plan and perform certain business for clients),
  • Service providers for companies and trusts or trustees when providing certain services (eg offering shelf companies),
  • Real estate agents are any persons who commercially arrange the purchase or sale of land or rights equivalent to real estate,
  • Organizer and broker of games.

In order to prevent money laundering, companies must obtain and document information about the identity of their contractual partners, who may be responsible for this person and the beneficial owner (know your customer principle – know your customer). They need to monitor their business relationships for abnormalities and take internal safeguards to detect money laundering leads.

For this purpose, a risk management system according to § 4  German MLA with risk analysis § 5 German MLA as well as internal security measures according to § 6 German MLA must be set up.

Outsourcing the Money Laundering Reporting Officer: You wish a free quote for your outsourcing of the MLRO. We are happy to help. Send your request directly to the S&P Money Laundering Prevention Compliance Team, Email: a.schulz@sp-partners.de

The most important changes and aggravations at a glance – Money Laundering Act 2017 – Outsourcing of the MLRO

Here you find further information about AML/CFT – German Version you find direct here:

§ 1 – Definitions – AML – CFT – German Version 

§ 2 – Obliged entities – authority to issue regulations – AML German Version

§ 3 – Beneficial Owner – AML German Version

§ 4 – Risk management – AML German Version

§ 5 – Risk Analysis – AML German Version

§ 6 – Internal Safeguards – AML German Version

§ 7 Anti-money Laundering Officer – AML German Version

§ 8 – Obliagtion – Recording and Retention – AML German Version

§ 9 – Compliance with obligation – AML German Version

§10 – Due Diligence Obligations with Respect to Customers – AML German Version

§11 – Identification – AML German Version

§12 – Verification of Identity – Authority to Issue Regulations – AML German Version

§13 – Procedure for verification

§14 – Simplified Obligations

§ 15 – Authority to Issue Regulations

Annex 1 – Factors of Potentially Lower Residual Risk

Annex 2 – Factors of Potentially Higher Residual Risk

§ 43 – Reporting Obligation of Obliged Entity

§ 44 – Reporting Obligation of Supervisory Authorities

§ 45 – Authority to Issue Regualations

§ 46 – Excecution of Transactions

§ 47 – authority to issue regulations

§ 48 – Release from Responsibility

§ 49 – Access to Information and Protection of Reporting Employees

§ 56 – Provisions Governing Fines

§ 57 – Publications of Final Measures

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