Key updates proposed include:
➡️ MLRO Authority & Independence: New wording reinforces that Money Laundering Reporting Officer #MLROs must have sufficient authority, autonomy, and unrestricted access to all information required to oversee AML/CTF activities;
➡️ Senior Management Delegation: Guidance on appointing or delegating responsibilities to another director or senior manager is clarified and strengthened;
➡️ Subject Access Requests : Updated data protection guidance clarifies the circumstances and considerations where ML/TF reports can be withheld or disclosed; and
➡️ Revised Timeframes: The former 40-day statutory deadline for data access responses is amended with a requirement to respond within one month, aligning with UK GDPR standards.
✅ Firms should review the proposed changes, assess impacts on MLRO oversight, and subject access request handling processes, and prepare internal updates ahead of finalised guidance.