The money laundering reporting officer: Some reflections from Malta
Abstract
The role of the money-laundering reporting officer (MLRO) has become increasingly complex and crucial in the face of evolving regulatory frameworks and rapid technological advancements. This paper examines the expanding responsibilities of MLROs, particularly within the context of the European Union’s new anti-money laundering (AML) supervisory framework and the proliferation of financial technology. It explores the multifaceted challenges faced by MLROs, including the need for technical expertise, regulatory compliance and proactive risk management in an era of heightened personal liability. The paper also highlights the transformative potential of artificial intelligence and data-driven solutions in enhancing AML/countering the financing of terrorism (CFT) processes, while emphasising the irreplaceable role of human judgement in addressing emerging risks. Furthermore, it underscores the ethical and legal considerations associated with the adoption of advanced technologies, particularly in relation to data privacy and civil liberties. Ultimately, this paper argues that the successful navigation of these dynamic challenges by AML/CFT professionals is essential to maintaining the integrity and resilience of the global financial system in an increasingly complex and high-stakes environment. This article is also included in The Business & Management Collection which can be accessed at https://hstalks.com/business/.
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Author's Biography
Christopher P. Buttigieg is the chief officer responsible for supervision at the Malta Financial Services Authority, a member of the Board of Supervisors of the European Banking Authority and European Securities and Markets Authority (ESMA), was the Chair of the ESMA Data Standing Committee (until December 2022) and is currently the Chair of the ESMA Proportionality and Coordination Committee. He is an associate professor at the Banking and Finance Department of the University of Malta and holds a PhD degree in law, focusing on financial regulation from the University of Sussex.
Eric Micallef is an assistant manager within the Financial Crime Compliance Function at the Malta Financial Services Authority (MFSA). His experience within the MFSA has revolved around the consideration of anti-money laundering/countering the financing of terrorism as part of prudential supervision and authorisation, contributing to policy initiatives, representing the MFSA in European Union fora, and supporting the authority’s training and outreach efforts.
