Appointing your compliance manager and compliance officer under the AMLR
Regulation (EU) 2024/1624 prescribes two named compliance roles for every obliged entity — including small Irish practices. Here is what each role does, how they differ from your current MLRO, and how a three-person firm can meet the requirement.
From 10 July 2027, the AMLR requires obliged entities to have a compliance manager at board (management-body) level and a compliance officer of sufficiently high standing who runs day-to-day AML compliance. From the same date, the compliance officer is also responsible for implementing targeted financial sanctions within the firm. Small firms can meet the requirement by formally designating existing senior people — but the appointments must be real, documented and resourced.
What is the difference between the compliance manager and the compliance officer?
The AMLR splits accountability from operation. One person answers for AML compliance at the top of the firm; another makes it work day to day.
The compliance manager
A member of the management body — in an Irish context, typically a director or a partner in the firm’s governing group. The compliance manager is accountable for the firm’s compliance with the AMLR at board level: making sure policies exist, are approved, and get the attention and resources they need.
The compliance officer
A person of sufficiently high standing who operates the framework day to day: policies and procedures in practice, due diligence quality, screening, training and reporting. From 10 July 2027 the compliance officer also carries responsibility for implementing targeted financial sanctions — screening against sanctions lists and acting on matches is squarely part of the job.
Neither role is the same thing as the Irish MLRO, though in practice they overlap. The MLRO is your reporting officer — registered on goAML and ROS, filing STRs. In many firms the compliance officer and the MLRO will be the same person. The point is that the AMLR names the governance roles explicitly, so “we all sort of share it” stops being an answer.
How do you appoint the two roles in practice?
Map the two roles against your current setup
Most Irish firms have an MLRO and little else formalised. List who currently owns AML policy, who handles day-to-day compliance, and who reports suspicions. You are looking for gaps between that reality and the AMLR’s two named roles.
Designate the compliance manager at board level
The compliance manager sits at management-body level — a director or equivalent who carries responsibility for the firm’s AML/CFT compliance at the top of the organisation. Record the appointment in a board minute or partners’ resolution.
Appoint a compliance officer of sufficiently high standing
The compliance officer runs the day-to-day: policies, procedures, controls and their operation. “Sufficiently high standing” means someone senior enough to act with authority — able to see files, question decisions, and escalate without asking permission.
Add targeted financial sanctions to the officer’s remit
From 10 July 2027, the compliance officer is also responsible for implementing targeted financial sanctions within the firm. Write sanctions screening and escalation into the role description now, so the responsibility does not arrive unowned.
Document both appointments and the reporting line
Record who holds each role, from what date, and how the compliance officer reports to the compliance manager and the board. Your policy pack and Business-Wide Risk Assessment should name both roles, not just “the MLRO”.
Resource the roles
An appointment on paper is not compliance. Both role-holders need time, training and access to the firm’s client records, screening results and reporting workflows to actually do the job.
How does a small Irish firm handle two prescribed roles?
Most Irish designated persons are small: a sole-principal accountancy practice, a two-partner solicitor firm, a family estate agency. The AMLR’s roles still apply, but they scale with the firm. In a small practice the sensible pattern is that a principal or director takes the compliance manager role, and a senior person — often the same person who already acts as MLRO — is designated compliance officer. In a sole-principal firm, one person may end up wearing more than one hat.
What matters is that the designation is deliberate and documented: named people, a dated appointment, a written role description that includes targeted financial sanctions from 10 July 2027, and evidence that the role-holder is trained and has access to what the job needs. Exactly how the requirement applies to the smallest firms is the kind of detail AMLA’s technical standards and guidance are working through — check amla.europa.eu and your sector supervisor’s guidance before finalising your structure, and take advice where your setup is unusual.
CompliDesk’s AMLR policy pack includes the compliance manager and compliance officer role designations as named fields, so both appointments are recorded where an inspector would look. Related reading: the STR dual-reporting guide covers the MLRO’s registrations.
Put names against the AMLR’s roles before 10 July 2027
See how CompliDesk records your compliance manager and compliance officer designations inside an AMLR-mapped policy pack — or join the waitlist for free early access.