A working queue for the person who carries the risk.
MLROs do not need another inbox. They need to know which matters genuinely require their judgement, in what order, with the full picture attached — and a way to record decisions that will still make sense at inspection two years later.
Referrals arrive prioritised, not chronological.
The queue orders referrals by what matters: sanctions exposure, SAR and DAML states, PEP involvement, enhanced due diligence, overall risk, proximity to exchange and how long the referral has been waiting.
Illustrative fictional queue. SAR and DAML-related matters are handled with restricted visibility — see tipping-off controls below.
Everything needed to decide, on one screen.
Recorded reasoning, not a tick-box
The MLRO writes the reasoning behind the decision in the workspace itself. Conditions — additional evidence, ongoing monitoring, EDD continuation — are attached to the matter and tracked like any other blocker.
The decision, its reasoning, its conditions and its timing become a permanent part of the matter record.
Six ways a referral can resolve — all recorded.
Approve
The matter proceeds; reasoning is recorded against the referral.
Approve with conditions
Progression is allowed subject to named conditions, which the system tracks to completion.
Request more information
The referral returns to the fee earner with specific questions; the matter stays blocked.
Maintain EDD
Enhanced due diligence continues, with the ongoing measures recorded on the file.
Refuse
The firm declines to proceed; the reasoning and timing are preserved on the record.
SAR / DAML state
Where a report is being considered or made, the matter enters a restricted state with separate visibility rules.
Assistance flows up. Accountability stays human.
- System assistance
findings, calculations, screening - Fee-earner review
accept, query, escalate - MLRO decision
approve, condition, refuse - Recorded reasoning
permanent on the matter
Nothing in the system approves a matter on its own. Every escalation ends with a named person and their written reasoning.
Client-safe by construction.
Internal risk assessments, referral reasoning and SAR or DAML activity are never exposed through the client portal. Client-facing tasks are generated in neutral, operational language, so completing the file cannot inadvertently disclose that a matter is under internal review.
Approval is not forever.
If the matter materially changes after an MLRO decision — a new party, a changed funding structure, fresh evidence contradicting the story — the earlier approval is flagged for re-review rather than silently carried forward. The trigger and the re-review both join the audit trail.
Next: proving all of this happened.
Every decision on this page ends up in a report an auditor can read — see how the file is assembled.