Designate an AML Compliance Officer with independent authority

AML Program policy, §4.1, §8.1

The Company designates, in writing, one individual as the AML Compliance Officer with full authority to administer, update, and enforce the program, to make escalation decisions, and to act as the sponsor bank’s point of contact, together with the resources and system access the role needs. The officer reports directly to the chief executive and enforces the program without needing the chief executive’s approval for individual compliance decisions. Any change of officer, including the move from an interim to a permanent hire, is designated in writing and notified to the sponsor bank.

Event-driven

At program launch, and on any change of officer; written notice to the sponsor bank on each change

Appoint the officer by written designation that states the authority and reporting line, notify the sponsor bank, and repeat both steps whenever the role changes hands.

• Officer designation

  Signed designation with the officer’s name, authority, and reporting line

• Sponsor bank notice

  Written notice of the designation and the bank’s acknowledgment

Chief Executive

Leela can hold the current designation record and flag when a change in the role has no notice to the bank on file.

Tell Leela about your company to see whether this applies.