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 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.