A reporting entity must designate an 'AML/CTF Compliance Officer' at management level. Given the differences in size, nature and complexity of businesses, 'management' may be interpreted broadly to mean a person who undertakes the handling, direction or control of AML/CTF compliance within a business. Under a joint AML/CTF program this officer can represent the entire designated business group. While the AML/CTF Compliance Officer should be at the management level, it is possible for the role can be incorporated with other duties and this may be a practical necessity in a small business. In larger or more complex organisations, the Compliance Officer's function may be supported by appointing additional staff to AML/CTF compliance activities. What does not change is the need for the responsibilities of the role to be clearly stated and these to be allocated.

In developing and describing the responsibilities of AML/CTF Compliance Officer position, a reporting entity should consider a number of factors including:

• independence
• seniority
• accountability
• reporting lines
• access to executive/board
• relevant skills and experience, including knowledge of the business and AML/CTF legislative obligations.