A reporting entity must appoint an Anti-Money Laundering and Counter-Terrorism Financing (AML/CTF) compliance officer. The compliance officer must be at management level and is responsible for making sure your business complies with its AML/CTF obligations.

Who can be an AML/CTF compliance officer

Your compliance officer should have the authority and resources to carry out their responsibilities effectively. This includes having:

• access to all relevant areas of your business
• access to all relevant employees
• the power to deal with any problems relating to your AML/CTF obligations
• any other resources needed to do their job.

The compliance officer may have other duties in the organisation.

If you are a sole trader or small business, you may get help or advice from an independent adviser, but you are still responsible for AML/CTF compliance.

AML/CTF compliance officers for designated business groups

If you are part of a designated business group (DBG) with a joint AML/CTF program, your compliance officer must be someone at management level in one of the member companies. In this case the compliance officer represents the whole group. They may also act as the nominated contact officer for the DBG.

If you are part of a DBG that chooses not to adopt a joint program, you must develop your own AML/CTF program and appoint your own compliance officer.

Delegating responsibilities

A compliance officer can delegate some duties to other employees in certain circumstances. For example, if a business has local branches or offices, the compliance officer may delegate some activities that are only performed in one of those local branches to make sure compliance procedures are implemented consistently at that branch.

Role of an AML/CTF compliance officer

Examples of duties a compliance officer may perform to ensure your business meets its obligations include:

• making sure your business complies with its AML/CTF obligations according to both the AML/CTF Act and AML/CTF Rules
• reporting regularly to your company’s board and senior management about how your business is meeting its obligations, including alerting them if your business is not complying
• taking day-to-day responsibility for your AML/CTF program
• helping to create, implement and maintain internal policies, procedures and systems for AML/CTF compliance
• being the contact point for your business’s dealings with AUSTRAC, for example submitting reports such as suspicious matter or threshold transaction reports, or liaising about compliance audits and other AUSTRAC requests
• addressing any feedback from AUSTRAC about how you are managing your risks or about your AML/CTF program.

We expect the AML/CTF compliance officer to have overall responsibility for the operation of your AML/CTF program even if they delegate some compliance functions.