RegSol Blog

Roles & Responsibilities of the AML Compliance Officer – EBA Guidance

July 2022

On 14th June 2022 the EBA published guidance on policies and procedures in relation to compliance management and the role and responsibilities of the AML/CFT Compliance Officer.

Frequently we have seen references to a European wide approach to AML/CFT (Anti Money Laundering / Countering the Financing of Terrorism). The aim of these guidelines is to “….create a common understanding, by competent authorities and credit or financial institutions, of credit or financial institutions’ AML/CFT governance arrangements. A common understanding, which is applied consistently and enforced as necessary, is key to strengthening the EU’s AML/CFT defences.”

The guidelines come into effect from 1st December 2022.

They are very comprehensive, running to 54 pages and they examine in detail the following:
  • The role of the management body in its supervisory function and management function in the AML/CFT framework.
  • Identification of the member of the management body responsible for AML/CFT.
  • Identification of a senior manager responsible for AML/CFT where no management body is in place.
  • Tasks and role of the member of the management body or senior manager responsible for AML/CFT.

Section 4.2 looks at the role and responsibilities of the AML/CFT compliance officer from their appointment, the skills and experience they should have in addition to the tasks they must complete and includes reference to outsourcing.

Section 5 has a list of additional documents, a summary of the Views of the Banking Stakeholder Group (‘BSG’) and Feedback on the public consultation and on the opinion of the BSG.

While reference is made to credit and financial institutions in the document, it provides useful information and guidance. As many of our readers will be aware, there is a positive obligation on Designated Persons to have a business wide risk assessment in place which covers all the AML/CFT and financial sanctions which their business may be exposed to. Included in the requirement is a specific reference to publications from the ESAs – European Supervisory Authorities. The EBA European Banking authority is one of these.

While we have provided an overview above, the link to the full document is here:

Guidelines on AMLCFT compliance officers.pdf (

If you require assistance in assessing your AML resourcing or in updating your Business Wide Risk Assessment and/or your AML Policies & Procedures, you can contact us at