AML / CFT Compliance Officer – a role not to be taken lightly
AML / CFT Compliance Officer is a key role in any organisation and any appointment to that role needs to be carefully considered. It is not a matter of simply assigning an employee, or oneself, to this role to demonstrate compliance with the AML / CFT Act.
A number of tasks, outlined below, need to be undertaken before the designated person can assume this role:
- Prepare a clearly defined role description, outlining responsibilities and authority.
- Update the person’s existing employment contract to include the new responsibilities.
- Vet the appointee. “Vetting” involves checking a person’s credit and criminal history. This can be done by undertaking a credit check (through agencies like Veda Advantage) and a Police check using the New Zealand Vetting service (visit http://www.police.govt.nz/advice/businesses-and-organisations/vetting for details). Although this person may have been vetted at the time they were recruited, their circumstances may have changed between then and now.
- As best practice, Strategi recommends reporting entities vet any person to be designated as the AML / CFT Compliance Officer and keep a record of it on the officer’s personal file.
- Train the person (both, initially and on an on-going basis) on the AML / CFT legislation, regulations, and other relevant matters such as identifying suspicious activities and knowing how to deal with them. This person will be the key contact between the AML / CFT supervisors (e.g. FMA, DIA and RBNZ) and your business, and they need to be able to demonstrate they are competent to fill the position.
- If the person appointed to this role is an authorised or registered financial adviser, the vetting done before the registration and/or authorisation may be sufficient to demonstrate the vetting requirement under the AML / CFT Act.
Contact us to discuss further, including a sample job description for the role.