The role of an Anti-Money Laundering (AML) Compliance Officer has evolved in tandem with the evolving landscape of AML, Terrorism Financing (CFT) and sanctions regulations, regulators’, shareholders’ and clients’ expectations as well as best practices as banks up their strategic move in combating financial crimes.

In institutionalising the organisation’s AML/CFT and Sanctions Policy, Framework, Risk Assessments Methodology and Programs, the AML Compliance Officer must not only take into consideration the country’s AML/CFT & Sanctions regulatory regime, but also the recommendations, guidance papers and best practices put forth by international bodies such as Financial Action Task Force (FATF), BASEL, as well as and regulatory regime such as Hong Kong Monetary Authority (HKMA), Monetary Authority of Singapore (MAS), Association Banks of Singapore (ABS), etc.

For an AML Compliance Officer to be respected by their business and support unit counterparts, senior management, regulators and peers as well as industry practitioners, there are some skillsets and attributes that a good AML Compliance Analyst should possess.

Here are the key skillsets and attributes of a good compliance professional: 

1. Ability to manage work pressure and stress

The work responsibilities and accountability of any compliance officer grow each year in tandem with increased regulations and requirements. As the financial crime landscape gets more complicated and money laundering, terrorist financing, proliferation and sanctions risks increase, the role of the compliance officer becomes more challenging.

Putting in place an AML/CFT framework and program that consistently remain robust will be difficult. Coupled with increasing expectations from senior management for more proactive and speedy responses, the compliance officer must have a mindset to stay calm and be able to manage pressure and workload.

A good principle to adopt is to remain objective without having a "time-clock" mentality to turnaround and manage cases quickly. Regardless of time pressure, he/she must ensure that the risk assessment or investigation process is thorough. Engage business partners early to raise any complexities and risks as well as to share any concerns. Both parties can then work together to resolve them. Cases that pose higher reputational and regulatory risks would have to be escalated to senior management.

2. Consistency and comprehensiveness

The assessment process must always yield consistent outcome and a good AML compliance officer should avoid a reputation as a "flip flop" decision maker.

In order to be comprehensive and thorough, he/she should adopt the "onion peel" approach where the case is stripped layer by layer till one drills down to the finest details. Fundamental details include:
  • who has the executive control in operations and decision making?
  • who are the counterparties?
  • where is that supply and buyer chain (where relevant)?
  • what is the business operating model?
  • where are the geographical locations of these identified counterparties?
  • do the geographical locations have any money laundering, terrorist financing concerns eg. corruption risks, ruling regime, goods or projects involved, transportation channels, etc.
Assessment process may yield a different outcome if there are incremental information. Therefore, the AML compliance officer must review and identify new information that may present any new incremental risks.


3. Strong knowledge of the organisation’s business strategy, products and services

The AML compliance officer should conduct adequate due diligence to understand the organisation’s business strategy including both short and longer term strategies, the product and services offered, the customer base (include target customer segment, if any), delivery channels i.e., how the services are offered to customers, the associated counterparties or partners, etc.

Having a sound understanding of the organisation's strategies, products and services will allow the AML compliance officer to better identify and assess the risks posed by each.

4. Good communication skills in both written and verbal skills

Effective communication is critical to delivering key messages to the audience.

The AML compliance officer must first identify the audience and key message that needs to be communicated. A good guide is to always adopt a consistent approach or format for delivery of the message such as main objective, target audience, important issues, risks and concerns that need to be addressed and their implications. Message should be concise and easy to understand.

5. Business enabler without compromising compliance principles

The AML compliance officer plays an important role in enabling businesses to pursue their goals. However, key principles must be observed consciously to ensure that the organisation does not facilitate any illegitimate fund flows or deal with customers that should be prohibited or poses regulatory/reputational risks to the organisation.

He/she should not be afraid to probe nor ask questions to gain good understanding of the business model, products or services offering, counterparties, etc. Any concerns should be made known to the business to ensure that they can better appreciate the queries posed to them without making them feel that he/she is being too intrusive or unreasonable.

6. Continuous acquisition of knowledge and skillsets

As the regulatory and business landscape evolves, new business products, services and functionalities are developed. The AML compliance officer must stay relevant by identifying new knowledge and skillsets eg. data analytics, to remain relevant.

Keeping abreast of latest technological tools available in the market will enable them to increase robustness of the AML/CFT framework and programs. It is also recommended that they establish adequate networks in the industry to gain insights into best practices as well as availability of new tools and technology that will enhance the key AML/CFT & Sanctions controls.

7. Forward looking

For the bank to sustain and manage new risks effectively, the AML compliance officer must be forward looking to identify emerging risks and prepare the bank to manage these risks on a proactive manner. Hence, it is important that he/she reads extensively to understand topics from the latest typologies trends to new business opportunities and incremental risks, in order to review these assessments and its applications, and relevance to the bank.

It is recommended that the AML compliance officer continuously engages business partners to understand their business strategy so that new risks can be identified with mitigating controls or risk acceptance at an early stage.


Written and contributed by Fairlen Ooi, OCBC