General information only. This article does not provide legal advice or determine whether a particular business or activity is regulated.

Operations Desk support

Under an Operations Desk engagement, the client’s internal AMLCO retains the formal appointment, accountability and material judgement. The Desk provides defined operating capacity around calendars, evidence, control monitoring, action tracking and management preparation.

Formal External AMLCO appointment

AUSTRAC guidance states that an AML/CTF compliance officer does not need to be an employee. If an external officer is engaged, that person must have the authority, resources and expertise to perform the role. Eligibility, fit-and-proper requirements, independence, conflicts and organisation-specific arrangements also need to be addressed.

Why the appointment path is gated

  • A separate documented suitability and capacity assessment is required.
  • The governing body retains its own oversight responsibilities.
  • Appointment terms, authority, resources, access and escalation arrangements must be clear.
  • Some organisations are better suited to an internal AMLCO supported by an Operations Desk.