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Outsourced MLRO

Outsourced MLRO: Designated AML Officer for Your Company

Appointing a Money Laundering Reporting Officer is a legal requirement for licensed financial institutions. The MLRO manages risks, identifies suspicious transactions, and ensures compliance with the new EU regulations: AMLA (2025) and AMLR (2027). This role is vital for payment systems, crypto-asset service providers, and brokers amid tightening European oversight.

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Cost of the service
from 550 EUR

Jurisdictions Where We Appoint MLRO

COREDO appoints outsourced MLRO in 14 jurisdictions: Czech Republic, Estonia, Poland, Lithuania, Latvia, United Kingdom, Germany, France, Spain, Austria, Cyprus, Malta, Singapore, Hong Kong.

Our MLROs have confirmed qualifications and are recognized by regulators in each country.

Comparison Table: Outsourced MLRO vs In-House Staff

Criterion	Outsourced MLRO	In-House MLRO
Annual cost	EUR 550–EUR 9,600	USD 150,000–USD 400,000+
Recruitment and training	Included	USD 50,000–USD 100,000
Continuity	24/7 on-call team	Vacation, sick leave
Report preparation	Monthly	As required
Policy updates	Based on regulatory changes	Periodically
Experience in multiple jurisdictions	Yes (8+)	Not always

Case Studies

Case 01E-Money Institution in Lithuania.

A newly licensed Lithuanian EMI required Bank of Lithuania-compliant MLRO appointment and AML framework setup. COREDO appointed an outsourced MLRO, developed comprehensive AML/CFT policies aligned to ECB guidelines, and established transaction monitoring protocols. MLRO appointed in 1 week; first Suspicious Activity Report filed within 30 days; Bank of Lithuania compliance certification maintained.

Case 02Cryptocurrency Service Provider in Czech Republic.

A CASP operator in Czech Republic transitioning to MiCA authorization needed MLRO services covering enhanced due diligence and sanctions screening for digital asset transactions. COREDO appointed a qualified MLRO within 10 business days, implemented AI-powered transaction monitoring protocols, and coordinated the authorization documentation with the CNB regulator throughout the process. Full MiCA compliance achieved in 3 months; zero AML violations recorded during the transition period.

Case 03Payment Institution Startup in United Kingdom.

A newly FCA-authorized UK payment institution required a nominated MLRO and comprehensive AML officer coverage for cross-border payment processing and fund transfers. COREDO identified and appointed an FCA-qualified MLRO within 3 weeks, coordinated the formal regulatory notification to the FCA, and established independent AML audit procedures. FCA acknowledgment received in 4 weeks; institution launched operations with complete regulatory compliance infrastructure in place.

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Outsourced MLRO Responsibilities

COREDO’s outsourced MLRO performs all functions of an in-house responsible officer:

STR/SAR Submission

receipt of internal suspicious transaction reports, their analysis, and transmission to national financial intelligence units (FIU) within established timeframes.

AML/CFT Program Supervision

monitoring of customer identification procedures, transaction monitoring, and risk assessment. Regular evaluation of AML system effectiveness.

AML Policy Review

updating internal regulations when legislation changes, including adaptation to AMLR 2024/1624 and AMLD6 (EU) 2024/1640 requirements.

Regulatory Interaction

representing the company in relations with FIU and supervisory authorities, preparing responses to inquiries, and assisting during inspections.

Staff Training

organizing trainings on AML procedures, suspicious activity identification, and internal reporting procedures.

Record Keeping

maintaining registers of STR/SAR, monitoring results, and other AML documentation in accordance with record-keeping requirements.

Who Needs Outsourced MLRO

MLRO outsourcing is suitable for the following companies:

licensed EMI, PSP, and CASP companies required by regulators to appoint an MLRO;

startups and fintech without budget for an in-house compliance officer;

companies entering new EU jurisdictions and needing a local MLRO;

investment funds and management companies;

companies acquiring ready-made companies with licenses (EMI, PSP).

MLRO/Compliance Officer Requirements Beyond the EU

While COREDO specializes in EU jurisdictions, global financial institutions often require AML/compliance officer structures in non-EU territories. Key requirements in major non-EU markets include:

Canada — FINTRAC (Financial Transactions and Reports Analysis Centre of Canada)

Appointed Officer: A dedicated in-house Compliance Officer is mandatory (full outsourcing is not permitted).
MSB Registration: All Money Services Businesses must submit the responsible officer’s details to FINTRAC.
Independent Audit: The compliance program must undergo an external review every 2 years.
STR Reporting: Suspicious Transaction Reports (STRs) must be filed within 30 days.

Dubai and UAE — Multi-Regulator Requirements

CBUAE (Central Bank): Requires two distinct roles — a Compliance Officer and a Money Laundering Reporting Officer (MLRO).
DIFC / ADGM: Mandatory appointment of a qualified MLRO with international certification.
VARA (Crypto): VASP licenses require an AML Officer with deep expertise in digital asset analysis.
goAML System: A unified reporting platform where the MLRO bears direct legal responsibility for all filings.

COREDO can provide advisory services on non-EU compliance structures and support preparation of compliance documentation for Canadian and UAE-regulated entities, though primary responsibility for officer appointment remains with the institution itself.

Service Pricing

The cost of outsourced MLRO depends on the number of hours needed to perform the responsible officer’s functions:

Volume	Package Price	Additional Hour Cost
5 h	EUR 550	EUR 110/h
10 h	EUR 1,000	EUR 100/h
20 h	EUR 1,800	EUR 90/h
40 h	EUR 3,200	EUR 80/h
80 h	EUR 5,600	EUR 70/h
160 h	EUR 9,600	EUR 60/h

For one-off MLRO tasks: Basic (up to 5 h) — EUR 130/h, Standard (20+ h) — EUR 100/h, Premium (80+ h) — EUR 80/h. AML Audit: from EUR 3,000/year.

All prices are listed excluding VAT.

How It Works

Current state assessment

analysis of the AML system, existing policies and procedures, identification of compliance gaps.

01

MLRO appointment

formal appointment of a COREDO responsible officer as the company’s MLRO, notification of the regulator.

02

Process setup

adaptation of the STR/SAR system, implementation of transaction monitoring procedures, team training.

03

Ongoing compliance

regular performance of MLRO duties: submitting reports, policy review, regulatory interaction, annual AML audit.

04

Our Experts

Grigorii Lutcenko

Head of Compliance (since December 2020) Head of COREDO's compliance team with 5+ years of experience in anti-money laundering legislation and risk management. Grigorii coordinates the outsourced MLRO function for all COREDO clients, develops comprehensive AML/CFT policies, and ensures interaction with financial intelligence units and national regulators. Education: Metropolitan University Prague.

Egor Pykalev

Senior Compliance Specialist (since February 2022) Senior Compliance Specialist at COREDO specializing in the operational execution of MLRO functions. Egor is involved in the analysis and preparation of Suspicious Transaction Reports (STR) and Suspicious Activity Reports (SAR), setup of transaction monitoring systems, and regular preparation of compliance reports for regulators.

Benefits of MLRO Outsourcing

Cost savings

outsourced MLRO costs from EUR 550/month versus USD 150,000–USD 400,000+ per year for in-house staff, with no recruitment, insurance, or tax costs.

International expertise

COREDO specialists have worked with companies in UK, Czech Republic, Estonia, Spain, Poland, Portugal, Hong Kong, and Singapore since 2016.

Continuity

a team of interchangeable employees: no interruptions for vacation or sick leave, any AML issue is resolved without delays.

Pay for results

fixed package cost defined in advance in the agreement: you pay for a specific outcome, not for working hours.

Comprehensive approach

MLRO integrates with COREDO’s full range of AML services: AML audit, KYC/KYB screening, training.

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Frequently Asked Questions

Can an MLRO be an external employee?

Yes, many EU jurisdictions allow appointment of an external MLRO provided they have the necessary qualifications, access to the company’s internal systems, and can perform duties without restrictions. COREDO ensures all necessary conditions for full-fledged outsourced MLRO operation.

What is the difference between MLRO and compliance officer?

MLRO is responsible for STR/SAR submission and ensuring compliance with AML legislation. Compliance officer is a broader role covering all regulatory requirements. At COREDO, outsourced MLRO covers AML functions; for complete compliance, additional support is available.

How long does MLRO appointment take?

The process includes evaluation of the current AML system, formal appointment, and process setup. Standard timeframe is 2–4 weeks depending on business complexity and regulator requirements.

What to do when changing regulators or jurisdiction?

COREDO adapts AML policies and MLRO procedures to new jurisdiction requirements. The team has experience working in 8+ jurisdictions and is familiar with local MLRO requirements in each.

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Find out if outsourced MLRO is right for your company — we will conduct a quick assessment of your compliance needs and propose a suitable package.

+420 228 886 867 · info@coredo.eu K Cervenemu dvoru 3269/25a, Prague, 130 00, Czech Republic