The Role of the AMLCO: Why Every Regulated Business Needs One

While the MLRO typically receives the most attention in discussions about AML/CFT governance, the Anti-Money Laundering Compliance Officer (AMLCO) - sometimes referred to as the Money Laundering Compliance Officer (MLCO) - plays an equally critical role in the day-to-day effectiveness of a compliance programme.

In the Isle of Man, the AML/CFT Code requires regulated businesses to appoint an AMLCO responsible for the ongoing monitoring and maintenance of the AML/CFT framework. The AMLCO’s responsibilities are distinct from, though complementary to, those of the MLRO.

Where the MLRO focuses on the assessment and reporting of suspicious activity, the AMLCO is responsible for ensuring that the wider compliance infrastructure functions as intended. This includes monitoring the implementation of AML/CFT policies and procedures, ensuring that customer due diligence processes are being applied correctly and consistently, overseeing staff training programmes and ensuring that training is appropriate to roles, conducting or coordinating internal compliance reviews and testing, reporting to senior management and the board on compliance performance, and maintaining and updating the business’s AML/CFT documentation as the business evolves or regulations change.

In practice, the AMLCO is often the individual with the deepest day-to-day understanding of how the compliance framework operates. They are the person who identifies when processes are not being followed, when staff training has lapsed, when policies need updating, or when customer risk profiles have changed in ways that require the business to adjust its approach.

For smaller businesses, the MLRO and AMLCO roles may be held by the same individual - though regulatory guidance generally recommends separation where practicable, particularly as the business grows. The rationale is straightforward: the MLRO’s reporting function benefits from independence and combining both roles in one person can create conflicts of interest or capacity constraints.

The outsourced AMLCO model is well-suited to businesses that need day-to-day compliance oversight but do not yet have the scale to justify a full-time in-house appointment. An experienced outsourced AMLCO can provide structured, regular oversight on a retainer basis, ensuring that the compliance framework remains effective and current.

At Kybri, we provide outsourced AMLCO services alongside our MLRO appointments. The combination ensures that both the reporting and oversight functions are covered by experienced professionals with genuine engagement in the business’s operations.