Internal Suspicious Activity Report Form and MLRO Register

How staff report money laundering concerns to the MLRO, and how the MLRO records evaluation, decisions, NCA reports, DAML requests and follow-up.

Editable Word document
7
10pages
Guidance notes included
aml consultancy solutions

Accountancy practice – compliance & management

Internal Suspicious Activity Report Form and MLRO Register

About this document

What it’s for

A confidential internal reporting form for staff, plus the MLRO’s evaluation record and a register of all internal reports. It helps staff meet their legal duty to report knowledge or suspicion of money laundering or terrorist financing to the firm’s nominated officer, and gives the MLRO a clear, defensible record of how each report was handled and why.

When to use it

  • Whenever anyone in the firm knows or suspects, or has reasonable grounds to know or suspect, money laundering or terrorist financing
  • When client due diligence cannot be completed and the MLRO needs to consider a report
  • When a possible sanctions match is found (the MLRO also considers sanctions reporting)

What’s inside

The document is laid out in the sections below. Each one comes with a plain-English guidance note explaining what it does and what to change.

  • Guidance for the person reporting
  • Part 1 – Report by staff member
  • Part 3 – MLRO evaluation
  • Part 4 – Report to the National Crime Agency
  • Part 5 – Action and follow-up

How to complete it

  • Staff complete Part 1 only, hand it directly to the MLRO and keep no copies
  • The MLRO completes Parts 2 to 5 and the register entry
  • Keep all forms in the MLRO’s confidential file, separate from client files, for at least five years

Key points to check

  • Never tell the client or anyone else about a report – that could be the offence of tipping off
  • Do not proceed with work that could be a prohibited act until the MLRO says you may

Our templates are professionally structured starting points for UK businesses, not legal advice. For anything complex, unusual or high-value, have your final version checked by a solicitor.

Included in the pack

Accountancy practice – compliance & management

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Editable Microsoft Word files

Guidance notes in every document

Written for UK businesses

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