Paragraph 9 of the „Compliance by banks at group level“, Working Drafts of the Council of the Commission, entitled „Compliance with the anti-money laundering directive by cross-border banking groups at group level“, dated 30 June 2009, there is mention to the obligation to implement „compliance” with the AML (anti-money laundering) legislation within the EU. Paragraph 10 explicitly states that the central role of AML within the banking organization has the anti-money laundering officer.
In most countries, MLRO (Money Laundering Reporting Officer) is of a binding nature. The position within the bank structure is discussed in point 11. „MLRO normally holds a high position within the company and is part of the compliance function, but MLRO will not necessarily be the chief of compliance.”