Designated compliance officer with day-to-day oversight of the program

Responsible for:

  • Designing, implementing, and changing the AML program

  • Communicating successes and failures to management

  • Creating training

  • Staying current with regulatory & legal changes

Some departments are just one person, others are split into strategic and operational (i.e. monitoring and reporting) aspects.

Possible subgroups in the department could include:

  • Investigations – which monitor automated alerts and referrals from other staff, files SARs

  • Business Support – performs CDD on higher risk clients, acts as a point of contact for queries

  • Oversight – reviews and updates the program and associated procedures, monitors the legal and regulatory environment. Coordinates regulatory exams with the business. May also prepare training and provide guidance on complex AML issues.

In addition, within the business, there are AML activities where there is customer contact e.g. CDD.




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