AML Outsourcing vs. Hiring an In-House MLRO – Which Is More Cost-Effective?

AML Outsourcing vs. Hiring an In-House MLRO – Which Is More Cost-Effective?

Introduction
Every obliged institution – from accounting firms to currency exchange offices and fintech companies – is required to appoint a person responsible for anti-money laundering compliance, known as the MLRO (Money Laundering Reporting Officer). In practice, many companies face a decision: is it better to hire a full-time MLRO or use AML outsourcing?

In this article, we compare both options in terms of cost, effectiveness, and risk.

Who is the MLRO and what are their responsibilities?
The MLRO is the person responsible for fulfilling the obligations under the Anti-Money Laundering and Counter-Terrorist Financing Act (commonly referred to as the AML Act). These responsibilities include:
- implementing and updating the AML procedure (the internal AML policy),
- supervising employee training,
- analyzing and reporting transactions to the FIU (e.g. GIIF in Poland),
- maintaining contact with supervisory authorities (such as GIIF or KNF),
- preparing the organization for AML inspections.
 
Option 1: Hiring an In-House MLRO
Advantages:
✅ Direct presence within the company
✅ Ability to respond quickly
✅ Easier integration of AML procedures into daily operations

Disadvantages:
❌ High cost – an experienced AML expert may cost between PLN 10,000 and 20,000 gross per month
❌ Difficult recruitment – this is a narrow specialization
❌ Risk of employee turnover and knowledge gaps
❌ Ongoing need for training and knowledge updates

Option 2: AML Outsourcing (MLRO as a Service)
Advantages:
✅ Lower cost – flexible cooperation model adapted to the company’s scale
✅ Access to a team of AML experts, not just one person
✅ Guaranteed compliance with current regulations and GIIF guidelines
✅ Complete AML documentation and inspection readiness
✅ Immediate implementation possible – no recruitment needed

Disadvantages:
❌ Less direct control over the function
❌ Requires good communication and clearly defined responsibilities

When is AML outsourcing the better choice?
✅ You lack internal resources to manage AML – your company has no one with sufficient knowledge of AML regulations, GIIF requirements, penalties, or procedures.
✅ You run a small or medium-sized business – the cost of hiring a dedicated MLRO is too high relative to your operational scale.
✅ You want to avoid spending time on recruitment and training – outsourcing allows you to implement AML immediately without searching for a specialist.
✅ You need complete AML documentation – internal policies, risk assessments, reporting templates, and notifications are ready to go.
✅ You care about staying up to date with regulations – external experts actively monitor changes to the AML Act, GIIF communications, and EU directives (e.g. AML Package, MiCA, TFR).
✅ Your company works with high-risk clients – experienced AML providers know how to classify clients and when to report them to GIIF.
✅ A GIIF or KNF inspection is coming – your outsourcing partner can prepare you for audits and help you communicate with regulators.
✅ You want to avoid financial penalties for AML violations – outsourcing minimizes the risk of costly compliance failures.
✅ You need recurring AML training with certification – the provider can deliver sector-specific training on a regular basis.
✅ You want one dedicated AML point of contact – a permanent AML advisor who knows your business and provides ongoing support.
✅ You want to integrate AML with ESG – companies like Ap Outsourcing Group offer a comprehensive approach to compliance that includes AML, ESG, and data protection in one place.

Conclusion: Which option is more cost-effective?
AML outsourcing is a practical and cost-efficient solution for most obliged institutions, especially in the SME sector. Hiring an in-house MLRO may be appropriate for large organizations that need a full compliance team on site.

Looking for AML support?
At Ap Outsourcing Group, we offer AML outsourcing, training, AML implementation, and audit preparation – in full compliance with the AML Act and GIIF/KNF guidelines. We work flexibly, effectively, and securely – from documentation to inspection readiness.