The Role & Responsibilities of the MLCO & MLRO

Start Time

08:30 AM

End Time

04:30 PM


Aruba, Caya Taratata 3-A, Unit 16.


All financial service providers must report the appointment of a new MLCO and/or MLRO to the CBA within one week after the appointment has taken place. The responsibilities are more precisely designated by our local regulator. The role of the MLCO and the MLRO carries significant responsibilities and can be challenging. For designated non-financial service providers CBA’s can inquiry questions concerning the appointment of a MLCO and MLRO concerning on their knowledge, experience and skills in the field of AML/CFT.

There are legal and regulatory obligations imposed by the Central Bank of Aruba (CBA). This training will provide guidance to the complex roles and responsibilities regarding MLCOs and MLROs recognized by the CBA.


Money Laundering Compliance Officer (MLCO)

According to article 47, paragraph 1, of the AML/CFT State Ordinance, service providers must employ a person in charge with the compliance with the laws and regulations in the area of AML/CFT. The MLCO should have a degree of seniority and authority within the business to drive policy decisions and actions.


Money Laundering Reporting Officer (MLRO)

According to article 47, paragraph 2, of the AML/CFT State Ordinance, service providers must employ at least one person in charge with the internal receipt and assessment of potential unusual transaction reports and the reporting of unusual transactions to the FIU.


  • Applicable legislation and regulations (legal requirements/CBA Handbook)
  • Who can be appointed as the MLCO (on management level) and the MLRO?
  • The qualifications of the MLCO and MLRO (financial and designated non-financial service providers)
  • Assessing the suitability of the appointed MLCO or MLRO
  • What entails having adequate knowledge, experience and skills related to AML/CFT?
  • Outsourcing the MLCO function – Content of the Outsourcing agreement
  • Is there a conflict of interest between the AML/CFT responsibilities of the MLCO or MLRO and any other responsibilities they may have?
  • Understanding the key MLCO’s and MLRO’s duties and responsibilities
  • Monitoring and sample testing of the effectiveness and adequacy of the policies, procedures and measures
  • Regular Compliance reports to Senior Management
  • Recognizing and identifying unusual/suspicious transactions and behaviors
  • Internal and external reporting procedures
  • The reporting obligation on the subjective indicators
  • The quality of Unusual Transaction Reports
  • The importance of the Civil and criminal indemnification (in Dutch: vrijwaring)
  • Request for further information by FIU
  • Which steps must be taken after an unusual transaction report has been submitted by the FIU to the relevant law enforcement agency?
  • Conducting an investigation – internet search – open sources
  • Assessing negative media information
  • Specific training followed by the MLCO and MLRO and by their deputies
  • Ensuring periodic retraining
  • Exiting clients – closing the account – rejecting new clients
  • The risk and consequences of Tipping Off – Confidentiality
  • Recordkeeping
  • Ongoing Monitoring – When and how to monitor?
  • Dealing with subpoenas and or search warrant – responding to Law Enforcement Investigations
  • Penalties for non-compliance – Who can be held responsible?

Target group

  • Anyone currently or considering becoming an MLCO or MLRO
  • Staff working within a compliance department especially those charged with AML monitoring, escalations/investigations
  • Internal Audit professionals
  • Risk Managers
  • Senior managers and top management would also derive considerable benefit from attending as they are the ultimate risk owners.


This full-day training is designed to fully explain the roles and responsibilities of an MLCO and MLRO. Practical advice and guidance will be provided on the responsibilities of the MLCO and MLRO and how those responsibilities can be achieved in a practical manner. Also, what is expected by the Regulator from the MLCO, MLRO and Senior Management. This training is highly interactive with discussions and case studies.


There are no requirements for participation.

Duration of the training

The duration of the training is 7 hours


AWG 770,- pp. (Incl. taxes)

Costs includes:  Training sheets, lunch and a Certificate of participation.


Date: September 22, 2021

Time: 8:30 AM – 4:30 PM

Location: This training will be held at the training center of Compliance Services Caribbean located at Caya Taratata 3-A, Unit 16 (Opposite RBC Bank Italiëstraat).