Can the Compliance Officer, Money Laundering Reporting Officer and the Money Laundering Compliance Officer carry out operational activities within a money service business?
The Codes of Practice for money service business allow – where operating volumes are at a level for it to be appropriate – for the roles of the Compliance Officer, Money Laundering Reporting Officer and the Money Laundering Compliance Officer to be undertaken by the same person. In small businesses, it is also possible that the Compliance Officer, Money Laundering Reporting Officer and the Money Laundering Compliance Officer may carry out operational activities within the money service business. That is acceptable provided that care is taken to ensure that there is no conflict between the various roles. For example, a person acting as the Compliance Officer for the money service business should not be responsible for monitoring his own compliance with the business’ operational procedures. In allocating roles to employees within a money service business care should be taken to ensure that the corporate governance arrangements and the internal control systems of the business are not comp
