AML 4 MSB 6. People and Liabilities

You must appoint a nominated officer. If you are a sole practitioner, then you are the Nominated Officer. (NO) The NO receives reports of suspicious activity from within the business and deciding whether to report to the National Crime Agency (NCA). The NO needs to be sufficiently senior within the business to make decisions on transactions. Oh, and they should be located in the UK.

Whether you need a compliance officer, depends on the size and complexity of your business. The compliance officer is responsible for ensuring the business is compliant with the Regulations. This might be an existing officer, taking on more responsibility, or it may be a new position. However - the person should be a director or equivalent or senior manager.

The compliance officer will audit compliance with the regulations such as:

  • actively checking adherence to the policies, controls and procedures
  • reviewing how effective these are
  • recommending and implementing improvements following such reviews
  • ensure compliance through the business with anti money laundering legislation and internal policies/procedures
  • oversight of relevant staff and agent screening

Her Majesty’s Revenue and Customs recommend that the compliance officer and nominated officer NOT be the same person, although it concedes that in a smaller business, this may not be practical.


You are an “officer” if you are:

  • a director, secretary, chief executive, member of the committee of management or a person who carries out that role in a business, even if you don’t have the title
    – a person in control of a business– any officer of association or any member of its governing body, or a person carrying out that role– a partner, any manager, secretary or similar officer of a partnership, or a person carrying out that role.

An officer in breach may be subject to a civil penalty AND a criminal one.

Serious stuff.

You must include all of the information above in your policies and procedures. If you would like Lime to cast an eye over yours, we will, for free. Get in touch.