Interim MLRO or AML project team? Roles, limits and requirements

Short answer: Yes, within limits. In Germany, the money laundering reporting officer (Geldwäschebeauftragter, GWB) can be appointed on an interim basis or the function can be outsourced; the appointment and any outsourcing must be notified to the supervisor in advance, according to BaFin practice at least two weeks beforehand (sections 6(7) and 7(4) of the German Money Laundering Act, GwG). In Switzerland, a financial intermediary may designate qualified external persons as its AML function (Geldwäschereifachstelle) if its size or organisation makes an internal unit impossible or disproportionate (Art. 25(4) of the FINMA AML Ordinance, GwV-FINMA). In both countries responsibility stays with the institution; staffing the role through staff leasing integrates the person into the institution's organisation.

This guide is for executive boards, heads of compliance and MLROs at banks, payment institutions, wealth managers and insurers in Germany and Switzerland. It explains when an interim MLRO is possible, what needs to be notified and when an AML project team is the better solution.

The options at a glance

When the AML function is absent or vacant there are three routes: fill the formal function on an interim basis, outsource it to a provider, or reinforce the existing function with a project team. The table shows what applies in Germany, Switzerland and, from July 2027, the EU.

Germany: the MLRO under the GwG, notification, deputy and outsourcing

Credit, financial services and payment institutions and other obliged entities must appoint an MLRO at management level and a deputy (section 7(1) GwG). The MLRO reports directly to the executive board; the board's responsibility remains.

What applies to an interim MLRO

• Notification: the appointment and removal of the MLRO and deputy must be notified to the supervisor in advance (section 7(4) GwG). BaFin generally regards notification as timely if it arrives at least two weeks before the person starts, and may request evidence of qualification and reliability (BaFin AML guidance, July 2025, section 3.2.1).
• Work in Germany: the MLRO must carry out the role in Germany (section 7(5) GwG). According to BaFin, a deputy may be based abroad if they act from Germany when deputising.
• Independence: the MLRO has unrestricted access to information and is not bound by instructions when filing suspicious activity reports. As a rule, the MLRO should not also be the data protection officer or part of internal audit.
• Protection against dismissal: the MLRO and deputy must not be disadvantaged in their employment because of their role. Dismissal is not permitted during the appointment or for one year after it ends, except where there is good cause for summary dismissal (section 7(7) GwG). The provision does not expressly say who counts as the employer for a worker supplied by an agency. The institution, the agency and the specialist should therefore align the length and end of both appointment and assignment before the start.
• Outsourcing: internal safeguards may be transferred to third parties after prior notification; responsibility stays with the obliged entity (section 6(7) GwG). According to BaFin this includes the MLRO or deputy function; both the provider and the individual must be notified. Such outsourcing always counts as material outsourcing.

German temporary agency work as a route

Under Arbeitnehmerüberlassung (German temporary agency work, here: staff leasing), the person is integrated into the institution's organisation and follows its instructions. That matches BaFin's expectation that the MLRO is subject to the directions of the responsible board member. The maximum assignment period of 18 consecutive months with the same client applies (section 1(1b) of the German Temporary Agency Work Act, AÜG). Whether a specific arrangement is notifiable outsourcing under section 6(7) GwG is for the institution to decide against MaRisk AT 9 and to document (BaFin guidance, section 3.10). Appointing the leased person as MLRO must be notified under section 7(4) GwG in any case.

Switzerland: the AML function under the GwV-FINMA and outsourcing

In Switzerland, the financial intermediary designates one or more qualified persons as its AML function (Art. 24 GwV-FINMA). The function advises line management and the executive board without relieving them of responsibility, prepares internal directives and plans training.

• Tasks: the AML function or another independent unit monitors compliance, sets the parameters for transaction monitoring, arranges the review of alerts and additional checks, and prepares the risk analysis (Art. 25(1) and (2) GwV-FINMA).
• Independence: an internal person with monitoring duties may not review relationships for which they have direct business responsibility (Art. 25(3) GwV-FINMA).
• External designation: under its own responsibility, the intermediary may designate qualified external persons if its size or organisation does not allow an internal function or this would be disproportionate (Art. 25(4) GwV-FINMA). For larger institutions an external AML function is therefore generally not an option.
• Reporting: the most senior executive body decides on reports to the Money Laundering Reporting Office (MROS) and may delegate this to the AML function (Art. 25a GwV-FINMA).
• Outsourcing at banks and insurers: operational compliance tasks can be outsourced in all supervisory categories, but institutions in categories 1–3 need an independent compliance function. Overall management, key leadership tasks and strategic decisions, including taking on and terminating client relationships, cannot be outsourced (FINMA Circular 2018/3, in force according to FINMA's list of current circulars).

Under Personalverleih (Swiss staff leasing), the agency transfers significant authority to give instructions to the client, and the specialist works integrated into the client's organisation (Art. 26 of the Swiss Recruitment Ordinance, AVV). Staff leasing is therefore generally not outsourcing under FINMA Circular 2018/3, which requires a provider to perform a significant function independently and on a permanent basis. The ordinance does not expressly say whether an AML unit staffed this way counts as internal or as an external person under Art. 25(4) GwV-FINMA. The institution should agree the classification with its audit firm before the start. Staff can only be leased into Switzerland by an agency based and licensed in Switzerland (Art. 12 of the Swiss Recruitment Act, AVG).

Interim leadership or operational support?

An interim MLRO is the right choice when the formal function is vacant or absent and nobody internally meets the requirements. Typical triggers are a departure without a successor, a long absence or a removal following audit findings.

• Interim MLRO or interim head of the AML function: takes on the role, the reporting line and the contact role towards supervisors and the financial intelligence unit. Requires appointment or designation and, in Germany, notification.
• Interim deputy: secures the function when the MLRO stays in post but needs relief or cover.
• Operational support: senior specialists work under the existing MLRO, for example on the risk analysis, directives, training or case work. No appointment is needed.

Alpinum Solutions provides professionals for formal functions and for operational AML work through staff leasing and freelancing, part-time or full-time. For the MLRO or AML function, regulatory requirements may rule out an external mandate or require staff leasing; statutory independence and responsibilities remain intact. More on our AML, KYC and financial crime compliance page.

When an AML project team is the better solution

An AML project team is better when the formal function is filled but work is piling up. The MLRO stays responsible; the team adds capacity and specialist knowledge.

• Backlogs: overdue KYC reviews or transaction monitoring alerts
• Remediation: measures arising from audit findings with deadlines
• Risk analysis: revision under new requirements, in Switzerland for example FINMA Guidance 04/2026 on the money laundering risk analysis
• Regulatory change: implementing the 2026 Swiss revision with the transparency register, or preparing for the AMLR

How to size such a team is explained in our guide to planning KYC remediation.

Outlook: the AMLR from July 2027

From 10 July 2027, the EU Anti-Money Laundering Regulation (AMLR) applies directly in all member states (Art. 90 Regulation (EU) 2024/1624). Two articles matter for staffing the function:

• Art. 11 AMLR: a member of the management body becomes responsible as compliance manager. The compliance officer (the MLRO) is appointed by the management body, needs sufficiently senior standing, acts as the contact point for authorities and reports suspicious transactions to the financial intelligence unit. Removal requires prior information of the management body and must be notified to the supervisor.
• Art. 18 AMLR: tasks may be outsourced if the supervisor is informed beforehand. Among other things, reporting suspicious activity to the financial intelligence unit may not be outsourced, except to an obliged entity in the same group and member state, and nor may approving the criteria for detecting suspicious transactions.

From 2027, the reporting task can therefore only be outsourced to an obliged entity of the same group in the same Member State. Under recital 47 AMLR, outsourcing means that a service provider itself takes over performance of a requirement. The AMLR does not expressly say whether an agency worker integrated into the organisation falls under this; institutions should clarify the classification with their supervisor before July 2027. In Germany, the Federal Ministry of Finance published a ministry draft of an Act implementing the Sixth EU Anti-Money Laundering Directive and strengthening money laundering prevention on 28 October 2026; according to media reports, it is to replace the current Money Laundering Act on 10 July 2027. Cabinet approval was still pending as at 31 October 2026. More in our guide to the AMLR and AMLA.

Limits and risks

• Responsibility for AML prevention stays with the executive board and the institution, even with outsourcing or an interim appointment (section 6(7) GwG; Art. 24 GwV-FINMA).
• Late notification in Germany is an avoidable deficiency. Allow at least two weeks' lead time.
• An interim MLRO without a deputy and a handover plan only shifts the risk. Succession and handover belong in the contract from the start.
• Alpinum is not a law firm and does not provide legal advice. Whether a specific arrangement is permissible is for the institution to clarify with its supervisor, audit firm and advisers.

Frequently asked questions about interim MLROs

Does BaFin need to be told about an interim MLRO?

Yes. The appointment and removal of the MLRO and deputy must be notified to the supervisor in advance (section 7(4) GwG). BaFin generally regards notification as timely if it arrives at least two weeks before the start. If the function is outsourced, the provider and the individual must also be notified.

Can a freelancer act as MLRO or Swiss AML function?

In Germany, outsourcing the MLRO function is generally possible after notification; the person must work in Germany. In Switzerland, external persons may act as the AML function only if an internal unit is impossible or disproportionate given size or organisation (Art. 25(4) GwV-FINMA). Depending on the institution, staff leasing rather than freelancing may therefore be required.

What does the AMLR change for the MLRO?

From 10 July 2027 the management body appoints the compliance officer, and a member of the management body becomes responsible as compliance manager (Art. 11 AMLR). Reporting suspicious activity may not be outsourced to external providers, except within the group in the same member state (Art. 18 AMLR). Removal of the compliance officer must be notified to the supervisor.

How long can an interim MLRO be deployed through temporary agency work?

In Germany, a temporary agency worker may be assigned to the same client for at most 18 consecutive months; earlier assignments count if the gap was three months or less (section 1(1b) AÜG). For a longer vacancy, succession should therefore be planned early. In Switzerland, the AVG sets no statutory maximum assignment period.

Next step

Tell us about the function, the institution and the time frame. Selected profiles are usually available within 48 hours; the start date is agreed jointly between the company and Alpinum, in Germany taking the notification period into account.

• AML, KYC and financial crime compliance
• Interim compliance: vacancy, project or backlog?
• The Swiss AML revision and transparency register
• Discuss your requirement

Last updated: 31 October 2026.