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8.1.2 Responsibilities

Effective from 13/7/2023

(AML-CFT Decision Article 21.1-5)

The specific tasks of the CO are detailed in the relevant provisions of the AML-CFT Decision. In general, the CO will collaborate with the relevant Supervisory Authority and the FIU to ensure that these can perform their respective duties. The CO’s tasks can be grouped broadly into the following categories:

ML/FT Reporting. The compliance officer is FI’s officer in charge of reviewing, scrutinizing and reporting STRs. In this capacity, the CO is ultimately responsible for the detection of transactions related to the crimes of money laundering and the financing of terrorism and of illegal organisations, for reporting suspicions to the FIU, and for cooperating with the Competent Authorities in relation to the performance of their duties in regard to AML/CFT.
 
AML/CFT Programme Management. The CO should ensure the quality, strength and effectiveness of the FI’s AML/CFT programme. As such, the CO should be a stakeholder with respect to the FI’s ML/FT business risk assessment, and the overarching AML/CFT risk mitigation framework, including its AML/CFT policies, controls and CDD measures. The CO is in charge of informing and reporting to senior management on the level of compliance and report on that to the relevant Supervisory Authority.
 
AML/CFT Training and Development. The CO is responsible for helping to establish and maintain a strong and effective AML/CFT compliance culture within the FI. This duty includes working with senior management and other internal and external stakeholders to ensure that the FI’s staff are well-qualified, well-trained, well-equipped, and well-aware of their responsibility to combat the threat posed by ML/FT.