AML roles and responsibilities

Why they matter

Clear responsibilities help your firm:

• Meet legal and regulatory requirements
  
• Avoid gaps or delays in decision-making
  
• Stay accountable and audit-ready
  
• Build a culture of shared compliance
  

Without role clarity, even simple AML tasks can fall through the cracks.

How to assign and manage AML roles

Key roles in most firms

Money Laundering Reporting Officer (MLRO)
Leads suspicious activity reporting and reviews internal alerts. Often also holds the Compliance Officer role.

Compliance Officer
Implements AML policies, runs internal training and audits, supports the MLRO.

Senior management
Approves AML strategy, resources, and high-risk decisions. Promotes a compliance-first mindset.

Frontline staff
Perform due diligence, stay alert to red flags, and report concerns.

Internal audit (if required)
Reviews AML controls independently, flags weaknesses, and monitors improvements.

Core AML responsibilities across the firm

• Customer due diligence (CDD): Verify client identity and assess risk
  
• Monitoring and reporting: Spot unusual activity and escalate it quickly
  
• Risk assessment: Understand your firm’s exposure and adjust controls accordingly
  
• Training and awareness: Make sure everyone knows their AML duties
  
• Record keeping: Keep documentation secure, complete, and accessible for five years
  

Create a culture of compliance

• Leadership should model good AML behaviour
  
• Keep roles and expectations clear
  
• Make procedures easy to follow and access
  
• Celebrate strong compliance and encourage open reporting
  

Common challenges and how to address them

Resistance to change is common when new AML procedures or technology are introduced. You can overcome this by explaining the reasons behind the change and offering clear, supportive training.

Maintaining strong client relationships while enforcing AML procedures can feel tricky. The key is using a risk-based approach and clearly communicating your firm’s legal obligations to clients.

Keeping up with regulations can be overwhelming. Subscribe to regular updates from HMRC and your supervisory body, and make it part of your process to review and update your AML approach regularly.

Resource constraints often hold firms back. Use technology to automate where possible, adopt practical templates, and focus on proportionate processes based on risk.

Summary

Everyone in your firm has a role in AML — and when those roles are clearly defined, compliance becomes smoother, faster, and more effective. Appoint the right people, train them well, and make compliance part of your everyday operations.

This article was summarised by the Firmcheck content team. The original content was written by independent AML expert Ian Waters and is available on our blog.

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