By a communique dated 9 June 2022, the Financial Services Commission indicated that it has amended its Competency Standards issued under Section 7(a)(a) of the Financial Services Act 2007. The changes brought seek to assist financial Institutions when considering the appointment of any new Money Laundering Reporting Officer, a Deputy MLRO and a Compliance Officer.

The important point to note is that the Financial Services Commission expects any appointed Money Laundering Reporting Officer, Deputy MLRO or Compliance Officer to have sufficient experience prior to appointment, namely:

  • The officer shall hold relevant experience of at least 5 years in the industry;
  • Alternately, the Commission may consider relevant experience of at least 3 years in the industry subject to the submission of relevant and valid AML/CFT professional certification*; and
  • Notwithstanding the above, for the purpose of Section 4.6 of the Competency Standards, the officers shall demonstrate a minimum of 10 years of relevant experience in the industry.

* The Financial Services Commission may consider the following AML/CFT certification: the Financial Services Institute (FSI), the Certified Anti-Money Laundering Specialist (ACAMS), the International Compliance Association (ICA) or any other certifications meeting the global AML/CFT requirement standards which may be considered by the Commission.

Should you require further information on the contents of this article, please contact your usual team member at Appleby or the undersigned parties.

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