Dual Roles, Double Risk? - Navigating the Compliance Risk of Being a Fee-Earning MLRO

Introduction

In many small to mid-sized law firms, it is common for the Money Laundering Reporting Officer (MLRO) to also carry out a fee-earning role. While this may appear commercially efficient, it creates a range of regulatory, ethical, and operational risks.

Balancing commercial targets with legal and compliance obligations can compromise an MLRO’s objectivity, increase the risk of conflicts of interest, and expose the firm to heightened regulatory scrutiny.

During this new virtual classroom seminar expert speaker Mandy Hargun will explore the risks associated with holding dual roles and provide insight into how regulators view fee-earning MLROs.

Mandy will also share practical tools to help law firms reduce risk, maintain compliance, and structure roles and responsibilities in line with best practice — protecting both the firm’s integrity and its regulatory standing.

What You Will Learn

This live and interactive session will cover the following:

• Understanding the MLRO's role in a law firm
• Core responsibilities under the AML Regulations
• The need for independence and impartial judgement
• Regulatory expectations from the SRA
• The conflict of interest - Fee Earner vs. MLRO
• Balancing billable hours with compliance duties
• Risk of bias when reviewing client matters one is personally involved in
• Scenarios where objectivity is undermined
• Managing the risk
• Creating clear role separation or delegation policies
• Implementing peer review or escalation procedures
• Leveraging deputy MLROs and compliance staff effectively
• Practical solutions for smaller firms
• How to meet regulatory requirements without excessive burden
• Outsourcing, consultancy support, and tech assisted compliance
• Templates for role descriptions, conflict checks, and reporting lines

Recording of live sessions: Soon after the Learn Live session has taken place you will be able to go back and access the recording - should you wish to revisit the material discussed.