A licensed agent suspects a client's premium comes from crime and reports it to her company's MLRO under its procedures. Her statutory reporting obligation:
Answer: has been fully satisfied. Once staff report suspicion to the MLRO under the institution's procedures, their statutory obligation is fully satisfied (OSCO s.25A(4)).Why not the others:• also needs a report from her to the IA: the report route is internal, then JFIU.• is suspended until the MLRO has decided: it is discharged, not suspended.• is met when the JFIU acknowledges the report: acknowledgement is not needed.Watch out: Thinking frontline staff must also report directly to the JFIU.Rule: The MLRO evaluates internal reports and, if there are grounds, discloses to the JFIU as soon as reasonable.Source: IA P1 Study Notes 2024 Ed. §7.4.7h, p.7/27; Organized and Serious Crimes Ordinance (Cap. 455) s.25A (e-Legislation, checked 31 Oct 2026)
Thinking frontline staff must also report directly to the JFIU.
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