Compliance Officer & Compliance Manager (AMLR roles)

What it is

Regulation (EU) 2024/1624 (AMLR) — the directly applicable EU single rulebook — prescribes a two-role compliance structure for obliged entities:

• A compliance manager at board level, accountable for the entity's compliance with its AML obligations.
• A compliance officer of sufficiently high standing, responsible for the day-to-day operation of the AML policies, controls and procedures.

From 10 July 2027, the compliance officer also becomes responsible for the implementation of targeted financial sanctions — meaning sanctions screening and the handling of matches move formally into the same prescribed role, rather than sitting wherever they happened to land historically.

Why it matters for Irish firms

Irish designated persons have run for 15+ years on the CJA 2010-era model, where the MLRO is the recognisable centre of gravity and other responsibilities are distributed by custom rather than prescription. The AMLR replaces custom with structure: the roles exist because the regulation says they must, one of them sits at board level, and both need to be designated, documented and resourced. For a small accountancy practice, solicitor firm, estate agency or TCSP, the same people may well end up holding these roles alongside existing duties — but "we never wrote it down" stops being a workable answer once a supervisor asks who the compliance manager is.

The sanctions dimension deserves particular attention. Wrapping targeted financial sanctions into the compliance officer's remit means screening arrangements, escalation routes and evidence of checks all need an identifiable owner from day one of the new regime.

What changes under the AMLR

This is itself one of the headline AMLR changes: prescribed roles arrive on 10 July 2027, the same day the AMLR replaces the substantive rulebook Irish firms have worked under. Updating the firm's policies to name the compliance manager and compliance officer — and to record the sanctions responsibility — belongs on every AMLR readiness plan, not on the post-deadline snag list.

How CompliDesk helps

CompliDesk Ireland builds compliance manager and compliance officer designation into its AMLR policy pack, with sanctions screening in the same platform — see the AMLR explainer for the full list of changes.