A Critical Analysis of the Effect of the Double Criminality Test on Nominated Officers and Money Laundering Reporting Officers (MLRO) in the Regulated Sector

24 Pages Posted: 7 Jul 2014 Last revised: 25 Jan 2015

See all articles by Ehi Esoimeme

Ehi Esoimeme

University of Wales System - Cardiff Law School

Date Written: October 30, 2013

Abstract

This paper critically discusses the effect that the new double criminality test has on Nominated Officers and MLRO's in the Regulated Sector. It looks at the difficulties the new double criminality test is likely to create for the Nominated Officers, addressing issues like 'when to report and not to report' and 'risk posed by changes to laws/regulations'. It then looks at the difficulties the new double criminality test is likely to create for the MLRO's as regards the execution of their duties. It does this by addressing the issue of 'difficulty in training staffs.'

Keywords: Single criminality, double criminality, money laundering, criminal conduct, criminal property, summary offences, indictable offences, either way offences, reporting, training staffs, Nominated Officer

Suggested Citation

Esoimeme, Ehi, A Critical Analysis of the Effect of the Double Criminality Test on Nominated Officers and Money Laundering Reporting Officers (MLRO) in the Regulated Sector (October 30, 2013). Available at SSRN: https://ssrn.com/abstract=2462952 or http://dx.doi.org/10.2139/ssrn.2462952

Ehi Esoimeme (Contact Author)

University of Wales System - Cardiff Law School ( email )

PO Box 427
Cardiff, Wales CF10 3AX
United Kingdom

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