The compliance manager at board level: who, what and how to evidence it
Article 11 AMLR requires a compliance manager in the management body next to the compliance officer. What the role involves, how it differs from the compliance officer and what supervisors will ask to see.
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Most obliged entities have a compliance officer. Fewer have a member of the management body who is personally responsible for AML compliance. Article 11 of the AMLR requires both. The compliance manager is the member of the management body, in its management function, who is responsible for implementing the regulation; the compliance officer is appointed by the management body and runs the day-to-day programme.
The compliance manager
The role is a responsibility, not a job title. It sits with an executive director or, in a two-tier structure, with a member of the management board. That person ensures that the policies, procedures and controls of Article 9 are in place and effective, that the compliance officer has the resources and access needed, and that the management body receives the information to steer. Where the entity is part of a group, the group-level compliance manager coordinates.
The compliance officer
The compliance officer is the operational head: monitoring, reporting to the FIU, training, the relationship with supervisors. The AMLR requires the officer to report to the management body at least once a year on the state of compliance, and to be able to escalate directly. Independence and sufficient seniority are expected; the Guidelines on internal policies, procedures and controls, now in final draft, add the detail on resources and reporting lines.
What supervisors will ask to see
- The appointment: a board decision naming the compliance manager, and the fit-and-proper assessment where the supervisor requires one.
- The reporting: minutes showing that the annual compliance report was presented and discussed, and what the management body decided.
- The mandate of the compliance officer: written, with access rights and escalation routes.
- Resourcing: how the officer's request for people and tools was handled.
Pitfalls
Making the chief executive the compliance manager by default without giving the role content; combining the compliance officer with a first-line role that creates a conflict; or treating the annual report as a formality without decisions.
What to do now
- Decide who the compliance manager is and record it before the implementation programme reports to the board again.
- Give the compliance officer a written mandate aligned with the draft Guidelines.
- Put the annual AML report on the board calendar with a fixed agenda: risk assessment, control effectiveness, findings, resources.
The dashboard tracks the internal-controls Guidelines under Governance; the readiness tracker has a block for the compliance function.