What is a Compliance Officer and Alternate Compliance Officer
Every Supervised Entity (non-regulated financial institution and listed business) must appoint a Compliance Officer (CO) and alternate Compliance Officer (ACO).
The CO is considered the guardian of the businesses’ AML/CFT compliance regime with ultimate responsibility for implementation of AML/CFT policies and procedures approved by directors/senior management. Additionally, the CO is the only employee authorized to submit suspicious transaction reports to the FIUTT.
The ACO performs the function of the CO only in their absence. This ensures continuity of the CO functions and the business reporting obligations.
Who can be appointed as the CO and ACO
The CO and ACO for each Supervised Entity plays a critical role in every business AML/CFT system. This means the appointed employee must well trained and suitable to perform the tasks. Additionally, the CO must be an employee with decision making authority.
For more information on who can be the CO and ACO, consult the following guidance note:
Approval of the CO and ACO
The CO and ACO appointed by senior management must be approved by the FIUTT. The FIUTT approval process only commences upon receipt of the Compliance Officer Fit and Proper Questionnaire [insert link to form]. All relevant internal processes and checks are then conducted. The entity is then provide with written notification of the FIUTT’s decision.
The approved Compliance Officer of an entity is the official liaison between the entity and the FIUTT.