Every reporting entity must designate an AML Compliance Officer (AMLCO) in writing. The role is named in your Part A program, holds operational responsibility for the program's effectiveness and is the primary point of contact for AUSTRAC.
Statutory and practical duties
- Maintain and update the AML/CTF program.
- Approve or escalate higher-risk customer onboardings.
- Review and submit SMRs and TTRs.
- Coordinate annual training and the independent review.
- Report to senior management or the board on program effectiveness.
Time commitment for an SME
For a 5–20 person firm with mostly low-risk clients, the AMLCO role consumes 4–8 hours per week — concentrated around onboardings, SMR escalations and quarterly reviews. Most firms combine it with a senior fee-earner or office manager role; the legal point is that the person must be sufficiently senior to escalate decisions and resourced to do the job.