Nominated Officer

CORE RESPONSIBILITIES 

The responsibilities of the ‘Nominated Officer’/‘Compliance Officer’ should include, but are not limited to:

Policy & Procedure Development & Implementation

• develop, document and update policies and procedures and disseminate information to the company’s personnel;
• develop, document, disseminate and implement disciplinary actions to be taken for breaches of the operator’s AML policies;
• assist the organization with the implementation of the compliance programme;
• develop procedures to conduct Employee Due Diligence and to ensure employees are adhering to AML requirements;
• oversee administrative matters related to compliance with AML/CFT functions;
• evaluate the potential level of money laundering and terrorist financing risk associated with the operation of the business

Training

• ensure that you are fully knowledgeable of the POCA and all related regulations;
• ensure the establishment and implementation of scheduled on-going training for all levels of staff;
• ensure training in preventing and detecting money laundering and the financing of terrorism for newly recruited staff immediately upon assuming employment with the organization;
• develop training material and scheduling, coordinating and record-keeping of AML/CFT training;
• advise the company of any proposed or pending regulatory changes.

Reporting

• establish and publicize a reporting system where other employees can confidentially report suspicious activities within the company without fear of retribution;
• receive reports on transactions or activities which are known or suspected to be money laundering or terrorist financing;
• maintain reasonable access to other information that may be of assistance in considering the reports;
• evaluate reports of suspicious/unusual transactions by staff and filing such reports with the prescribed authority;
• filing of Suspicious Transaction Reports (STRs) to the Designated Authority;
• prepare reports to Senior Management, Board of Directors and Regulatory/Supervisory Authorities;
• responsible for ensuring that recommendations from any examinations by the Competent Authority and any external audit are promptly reported to the relevant internal body for review and once approved, are implemented.  

Monitoring

• observe and ensure implementation of internal controls and procedures;
• conduct regular monitoring and analysis of customer transaction activities;
• observe and investigate any display of suspicious behavior or drastic lifestyle changes seen in employees;
• develop a method for conducting regular risk assessment of customers to determine the need for Enhanced Due Diligence;
• coordinate Enhanced Due Diligence process regarding high risk clients;
• coordinate annual audit of the AML/CFT programme to ensure compliance with all laws and requirements;
• ensure reviews are carried out, with the aid of the system implemented which can highlight certain types of unusual/potentially fraudulent activities, of customer accounts, daily transactions, etc. 

Compliance

• act as liaison between the company and the regulatory and laws enforcement agencies with respect to compliance matters and investigations;
• upon detection of any offence, take all reasonable steps to respond appropriately to the offence and prevent similar offences including modifications to the programme to  prevent and detect violations of law 

• The ‘Nominated Officer’/‘Compliance Officer’ also has responsibility for the supervision of Record Retention requirements and the security of all records maintained in relation to the AML/CFT programme.