Section 14 of the PVARA NOC Regulations 2025 explicitly permits an outsourced, cross-border Money Laundering Reporting Officer. KYCifi provides this service from £750 per month — named MLRO on your PVARA application, signing Form A4 alongside your CEO.
Section 14 of the PVARA NOC Regulations 2025 states that AML-critical functions including MLRO responsibilities may be outsourced provided the applicant: (a) conducts due diligence on the service provider; (b) maintains effective oversight arrangements; (c) retains audit and inspection rights; and (d) ensures legal enforceability of audit and supervisory rights including cross-border arrangements.
Section 3(xv) of the Virtual Assets Act 2026 defines Key Individual to include the MLRO on an "outsourced basis". The Pakistan residency requirement under Section 20(6) applies to at least one Key Individual — it does not specifically require the MLRO to be the Pakistan-resident individual.
We are named as your MLRO on your PVARA NOC application, Form A8, and Form A4 — co-signed with your CEO to satisfy the dual-signatory requirement.
Form A4 (AML/CFT Framework Submission Statement) must be jointly signed by your CEO and MLRO. We provide that signature as your named, appointed MLRO.
We sign your Form A6 Annual AML/CFT Return each year and provide the MLRO Annual Statement on your compliance status — a regulatory obligation from day one of licensing.
We advise on suspicious activity escalation, support goAML filing processes, and provide MLRO-level review of complex cases requiring senior compliance judgement.
The fractional MLRO service provides the named MLRO function and regulatory sign-off. It does not replace an in-house compliance team for day-to-day transaction monitoring, customer onboarding decisions, or alert management. We will always advise you clearly on what additional in-house resource you need alongside the fractional MLRO service.
12+ years financial crime compliance experience
Former KPMG · Deloitte · Bank of New York · Eversheds Sutherland
Manchester-based UK jurisdiction — legally enforceable cross-border arrangements
PVARA regulatory specialist — NOC Regulations 2025 and Virtual Assets Act 2026
Take our free 3-minute PVARA gap assessment first — it will show you exactly what documents you need and where the fractional MLRO fits into your application.