Role Guide

Section 250 and the MLRO: What You Need to Know

The MLRO sits at the intersection of AML obligations and Section 250 scope. As an individual holding a Controlled Function (CF11), you are already on the FCA register — but Section 250 creates two distinct responsibilities for you: ensuring your own declaration is in order, and participating in the firm's broader gap analysis to identify uncovered individuals who may present AML and financial crime risk.

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TL;DR

The MLRO sits at the intersection of AML obligations and Section 250 scope. As an individual holding a Controlled Function (CF11), you are already on the FCA register — but Section 250 creates two distinct responsibilities for you: ensuring your own declaration is in order, and participating in the firm's broader gap analysis to identify uncovered individuals who may present AML and financial crime risk. CoverProof automates the SM&CR gap analysis, zero-login declarations, and litigation-grade evidence pack generation that MLROs need to complete before the June 29, 2026 statutory deadline under Section 250 of the Crime and Policing Act 2026.

Your Section 250 obligations

1

Your own Section 250 status

As a CF11 holder, your SM&CR status may already be documented — but Section 250's broader definition of "significant role" means you should confirm that your specific responsibilities are covered by the existing declaration framework, not just assumed to be.

2

Identifying financial crime risk in the uncovered population

The individuals who fall into the Section 250 gap are, almost by definition, senior people with financial authority who are not subject to existing regulatory oversight. As MLRO, flagging this population and ensuring they are brought within the declaration cycle is part of your financial crime risk framework.

Your pre-June 29 checklist

  • □Confirm your own SMF/CF designation covers your current responsibilities
  • □Participate in the firm's Section 250 gap analysis
  • □Review the uncovered-individuals list for financial crime indicators
  • □Ensure all individuals in the gap have completed declarations
  • □Document the analysis in your financial crime risk framework
  • □File a note in the SAR consideration log if any refusals occur

Common questions

Does Section 250 create any new SAR obligations for MLROs?

Not directly. Section 250 creates compliance and criminal liability obligations, not new SAR reporting triggers. However, if a refusal to provide a Section 250 declaration is connected with suspected money laundering, that refusal may be relevant to your SAR consideration obligations.

I am a part-time MLRO at a small firm. Do I still have Section 250 obligations?

Yes. Your Section 250 obligations arise from the firm's authorisation status and your individual role, not from your contract type. A part-time MLRO at an FCA-authorised firm has the same obligation as a full-time one.

Bring your Section 250 framework into your financial crime programme.

CoverProof's gap analysis and declaration cycle integrates naturally with your MLRO responsibilities. The evidence pack documents both the analysis and the outreach — exactly what a regulator would expect to see.

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