Accountable institutions which are not legal persons (excluding sole proprietors) must appoint someone with sufficient competence and seniority to help the Board of Directors or senior management exercising the highest level of authority in the business. The appointed person’s role is only to ‘assist’ the accountable institution (and/or top management) in complying with the provisions of FICA.
The MLCO reports directly to the board or to another senior executive who in turn reports to the board.
In order to sufficiently support the board, the MLCO must have an understanding of the board’s role and responsibilities..
The MLCO should keep the board apprised of key developments in RMCP, potential risks and vulnerabilities, any flaws and the ways in which they are being addressed, applicable impending legislation and its impact and the overall health of the program.
This person would generally oversee and implement an ongoing AML training program for employees..
The ability and dedication of an AML Compliance Officer will shape your AML program, and reflect your institution’s commitment to combating financial crime. With that in mind, when appointing an AML officer, the following factors should inform your decision: