What Brokers and Lenders Must Know
FCA authorisation carries obligations around AML compliance. Lenders are typically required to appoint a Money Laundering Reporting Officer (MLRO) under the Senior Managers and Certification Regime (SM&CR), whereas brokers must appoint a registered AML person, even if they do not handle client funds directly.
MLRO / Registered Person Responsibilities
- Receive and investigate Suspicious Activity Reports (SARs).
- Ensure staff training to detect money laundering.
- Maintain AML policies and procedures.
- Report issues to senior management, FCA, or NCA.
Differences Between Brokers and Lenders
Credit Brokers:
- No SMF17 requirement.
- Must appoint a registered AML person.
- Focus on due diligence on introducers and client verification.
Lenders:
- MLRO is an SMF17 role under SM&CR.
- Responsibilities include monitoring lending transactions, reviewing complex structures, and maintaining AML records.
- Larger lenders may have dedicated AML teams reporting to the MLRO.
Registration Steps
- Identify the responsible individual.
- Submit the appropriate FCA forms.
- Document responsibilities in the Statement of Responsibilities.
How ALPH Legal & Compliance Can Help
- Advising on SMF17 registration and FCA submissions.
- Reviewing AML policies and oversight frameworks.
- Staff training and compliance implementation support.
ALPH Legal & Compliance can assist with all aspects of your business’s compliance needs, whether that be compliance structure and policy, internal/external audit, business and regulatory change support, authorisation, supervision or just some general expert advice and guidance!
With all the regulatory shifts on the horizon, now is the time to act. Don’t wait until compliance gaps appear—engage with ALPH Legal & Compliance today to ensure your firm is ahead of the curve. Whether you need tailored guidance, compliance support, or strategic insights to drive new business, ALPH Legal & Compliance is your trusted partner in navigating FCA regulations with confidence.
Contact ALPH Legal & Compliance now and take control of your compliance future!