On 8 December 2015, the FCA’s Head of Financial Crime, Rob Grupetta, delivered a speech in which he discussed, among other issues, the requirement for firms to provide a senior manager with explicit responsibility for dealing with financial crime.
Mr Grupetta noted that the FCA had encountered confusion amongst stakeholders as to how the requirement for a senior manager to be given “explicit responsibility for overseeing the firm’s efforts to tackle financial crime” would fit in with the role of the Money Laundering Reporting Officer (MLRO). He stated that the relevant senior manager should have overall responsibility for the firm’s policies and procedures, and that “this may or may not be the MLRO”. However, he further noted that if the two roles are not shared by one person, then the relevant senior manager’s responsibilities should include supervision of the MLRO. Finally, he added that “all senior managers of operational units in a firm should be taking reasonable steps to mitigate financial crime risk”.