By: CPA Susannie Kyamanywa, CAMS
Manager Quality Assurance & Regulations -ICPAU
Before you get into the role as a new Money Laundering control officer, you need to understand that A “Money Laundering control officer” is not just a position or a job description; it brings with it the responsibilities associated with protecting the organization (firm) and the global economy as a whole.
To assist entities in curbing financial crimes, the anti-money laundering (AML) regulations mandate all accountable persons to implement an AML/combating the financing of terrorism (CFT) framework. The responsibility of ensuring the development of robust internal AML policies, procedures, and controls, as well as effective implementation, has been entrusted to the Money Laundering control officer, also known as the money laundering reporting officer (MLRO).
The following eight ideas aim to help you embark on a fruitful and exciting journey where you can learn and at the same time prove to be a valuable asset to your organization. As you start the role of AML compliance officer, it is essential that you spend the initial days of your appointment on the points detailed below.
Make Time to Understand the organisation Business
For an MLCO to be effective, he/she must make time to learn and understand the business he/she is trying to protect. Writing policies, reading suspicious reports, monitoring and training become pointless if you do not understand the environment you are in and the needs of your peers at the front line. Take time to sit with them, engage in their day-to-day activities and make inquiries in regards to the challenges they face and issues with which they need help. Ask and be prepared to listen to what they have to say. That will help you truly understand what they are doing and how you can become a valuable and necessary partner.
There is No Shame in Training
Do not think that because you have been appointed in the MLCO role, further training is not necessary, mainly because you seem to have already proven that you are up to the challenge. I have news for you, this is not the case. There should be no shame in receiving training. Training should be continuous, even if you are repeating yourself. Try to find training opportunities in your area. Choose carefully and try to find those seminars or workshops that will help you in successfully discharging your duties. Trainings can even provide you with ideas for conducting your own training for your colleagues.
Evaluate staff training needs, including reviewing the past training logs and materials used.
Critically evaluate the existing AML procedures implemented in the organization and identify the gaps, if any, in its alignment with the AML regulations and identified money laundering and terrorist financing risks.
Know Your AML Regulations
As an MLCO, you must understand the relevant local AML/CFT laws and regulations applicable to your organization. You Should also look out for sector-specific AML guidelines issued by the relevant authorities such as ICPAU with which your organisation must comply. In addition, you should update yourself on all statutory amendments impacting the entity’s AML measures.
Invest time in understanding the recent money laundering and terrorist financing trends and typologies prevalent in different jurisdictions. Knowledge of the applicable AML regulatory framework would help you understand the obligations imposed on your organisation. In turn, you will understand your function as a MLCO compliance officer and what the local AML regulations demand of you.
Seek Resources Outside of Your Immediate "Environment"
The MLCO role requires a lot of critical thinking and analysis and accordingly I would advise you to set up your own library of guidance notes, training materials, presentations, articles and case studies. Organize these into folders and refer to them when you are uncertain about a situation or when you feel like confirming something before you make a business decision or provide advice.
Also, there are some useful and current books on AML and CFT, as well as general compliance management. They can be helpful both as a tool to get you started, but also as a reference, from time to time.
Network, Network, Network
Attending relevant conferences is a great way to meet with peers. Networking is very important in today's fast-paced environment. It is vital to exchange ideas, to share resources and experiences and to seek help. Also, social media is very important—use LinkedIn or even Facebook and X to follow professional bodies and professional membership organizations that share important news as they happen. You can then share what you have learned with your colleagues.
Remember to be open and welcoming, and embrace the challenges and prospects of your position and be prepared to make a difference.
Know the Compliance Culture
Review your organisation’s AML framework and the quality of the internal AML policies, procedures, and controls. Get insights into the organisation’s money laundering and terrorist financing risk appetite and the firm’s latest risk assessment.
More steps you should take are understanding the senior management’s support for AML compliance, obtaining the independent AML auditor’s report, and having a look. Review the observations highlighted by the auditor and understand the management’s stand on the same. Also, check if the regulatory authorities such as ICPAU and FIA have conducted any previous inspection, any AML noncompliance instances pointed out by the authorities and their status.
Schedule time to meet the preceding MLCO to seek their feedback about the organisation, their approach and their attitude toward AML compliance.
Know Your Resources
Meet the compliance team and understand their roles and responsibilities. Getting more insights from the team member’s experience, competence, and level of open communication can help you in the future.
Understand the AML tools and solutions implemented by the organisation for customer onboarding, transaction monitoring, and alert dispositioning and reporting of suspicious activities. These are important pieces of information that you may need.
Review the organization’s compliance budget in terms of the technology that the organization has invested in for anti-money laundering compliance and whether the organization has appointed an external consultant to review the implemented AML/CFT measures periodically.
Identify whether external AML consultants are appointed to assist the organization with their AML journey. If yes, learn about the consultant’s scope of work and the degree of their involvement in the organisation’s AML compliance function.
The time spent assessing your work and responsibilities will help you dive into your role as MLCO and ensure your organization is safe against money laundering and terrorist financing vulnerabilities. Lay down a solid foundation to make the organization 100% AML compliant and avoid regulatory fines and penalties.
Draw Your Action Plan
As a compliance officer, it is now your humble duty to ensure the effective implementation of the AML compliance program. No stone should be left unturned in your efforts to protect the organisation against money laundering and terrorist financing exploitation or reputational damage for being party to any money laundering activities.
Along with the plan of action, design the methodologies and tools (such as conducting quarterly reviews) to track the progress on the proposed enhancements and timelines.
