AML Officer Services

The roles

These are statutory regulatory roles. Cayman Islands regulated entities must appoint natural persons to each of the following, and this is the one place on the site where the terms are set out in full:

• AMLCO — the Anti-Money Laundering Compliance Officer, responsible for oversight of the compliance programme and the day to day point of contact on AML matters.
• MLRO — the Money Laundering Reporting Officer, who receives internal suspicious activity reports and decides whether they go to the Financial Reporting Authority.
• DMLRO — the Deputy Money Laundering Reporting Officer, who acts when the MLRO cannot.

Appointees must be individuals at an appropriate level of seniority, with the autonomy and the access to information the role actually requires. Elsewhere on this site these roles are referred to collectively as AML Officers.

What an appointment involves

• Accepting the appointment and handling the associated notifications
• Ongoing oversight of the entity’s AML framework
• Receiving, assessing and where appropriate reporting internal suspicious activity reports
• Attending board or governing body meetings as required
• Reporting periodically to the governing body on the state of compliance

Support for existing AML Officers

Not every engagement is an appointment. Where the roles are already filled in house, we provide additional technical and practical support to AML Officers and compliance teams: a second view on a difficult classification or escalation decision, cover during absence or transition, and help working through regulatory change as it lands.

Where we draw the line

Outsourcing the role does not outsource the obligation. The governing body keeps responsibility, and an appointed officer who cannot get information, cannot ask questions, or cannot escalate is not performing the role. They are lending a name to it.

We would rather decline an appointment than hold one on that basis. It is not a favour to anyone, least of all the entity, when a regulator asks what the officer actually did.