What Does a Compliance Officer Actually Do?

In short: a compliance officer oversees the business’s day-to-day AML/CTF compliance — managing escalations and customer due diligence, reporting to AUSTRAC, training staff, maintaining the AML program and preparing annual reports. Here’s a high-level summary of what the role involves.

Reporting entities must appoint an eligible person to be their compliance officer under the Anti-Money Laundering and Counter-Terrorism Financing Act 2006 (Cth) (AML laws).

The compliance officer is responsible for overseeing the business’s day-to-day compliance with its AML/CTF program and obligations. The specific obligations of the compliance officer will vary between businesses depending on the type of business and responsibilities set out in their individual AML/CTF Program. There are also some compliance tasks that are required to be completed by the compliance officer under the AML laws.

It is important that the compliance officer for a reporting entity understands both what the legislation requires but also what falls within their remit under their AML/CTF Program.

What Are the Core Responsibilities of a Compliance Officer?

Below is a general high-level summary of the responsibilities of a compliance officer:

Day-to-Day Oversight and Escalations

• Overseeing and co-ordinating day-to-day compliance with their AML Program and AML laws

• Supporting staff decision-making

• Reviewing escalations and unusual activity reports from staff

• Making decisions about escalations and when to stop or continue acting for a client

• Conducting enhanced customer due diligence for escalated matters

• Completing complex beneficial ownership checks when escalated

• Attending to offboarding clients or terminating their retainers

Reporting and Communicating with AUSTRAC

• Communicating with AUSTRAC

• Submitting SMRs, TTRs and CBMRs on behalf of the business

• Preparing and submitting the annual report to AUSTRAC

• Keeping up-to-date with the latest AUSTRAC communications and guidance materials

People, Due Diligence and Training

• Conducting personnel due diligence on employees

• Determining the content, delivery format and frequency of staff AML training

Maintaining the Program and Governance

• Maintaining the AML Program, including making any necessary updates to the agency risk assessment and policies when new risks emerge, new services are provided, an event occurs showing the agency that their program isn’t compliant or an independent evaluation makes an adverse finding about the agency AML program

• Conducting periodic effectiveness checks to ensure the AML program is working effectively for the business

• Preparing and providing the annual report to the Governing Body

• Arranging for the business’s independent evaluation

What Does a Typical Day Look Like?

Daily tasks may include answering enquiries from team members about individual client KYC checks that have been completed, reviewing escalations sent through by staff, making sure the relevant workflows are operating effectively for the team, making sure the systems/platforms are being used correctly and offering support and guidance to team members with AML questions.

Where Should a New Compliance Officer Start?

If you’ve been appointed as a compliance officer and you’re not sure where to start, review the AML/CTF Program of the business to firstly gauge what is expected of you for the specific business. From there, our week one AML/CTF roadmap sets out the first practical steps.

Common Questions

What reports does a compliance officer submit to AUSTRAC?

The compliance officer submits SMRs (suspicious matter reports), TTRs (threshold transaction reports) and CBMRs (cross-border movement reports) on behalf of the business, and prepares and submits the annual report to AUSTRAC.

Does the compliance officer handle every KYC check personally?

Typically no. Staff run day-to-day checks, and the compliance officer supports their decision-making, reviews escalations and unusual activity reports, and takes on the escalated work — enhanced customer due diligence and complex beneficial ownership checks.

What should a newly appointed compliance officer do first?

Review the business’s AML/CTF Program to gauge what is expected of you for the specific business — the role’s obligations vary between businesses depending on the responsibilities set out in each individual program.

Disclaimer

This article is provided for general informational purposes only and does not constitute legal advice. It reflects a general summary of publicly available guidance and is not a comprehensive or authoritative interpretation of the Anti-Money Laundering and Counter-Terrorism Financing Act, associated Rules, or any other legislation. Laws, regulations and regulatory guidance can change, and how they apply will depend on your specific circumstances. Before acting or relying on any information contained in this article, you should seek independent advice tailored to your situation.