AML/CFT and financial crime officer licence map

Who this helps

• - AML/CFT officers
• - MLRO candidates
• - Financial crime analysts
• - Sanctions officers
• - Startup compliance owners

Typical job titles

• - AML officer
• - Financial crime officer
• - MLRO
• - Sanctions officer
• - Transaction monitoring analyst

Core question

Does the person own or operate customer due diligence, sanctions, transaction monitoring, suspicious activity escalation, AML/CFT training, independent testing, or financial-crime reporting?

Activity triggers

• - The person designs or approves AML/CFT, sanctions, CDD, enhanced due diligence, or transaction monitoring controls.
• - The role reviews alerts, escalates suspicious activity, files or supports reports, or handles regulatory enquiries.
• - The applicant serves higher-risk clients, cross-border investors, private funds, digital onboarding, introducers, or complex ownership structures.
• - The role is named as MLRO, compliance officer, senior manager, responsible officer, responsible manager, or financial crime owner.
• - AML/CFT controls are outsourced, group-provided, vendor-led, or shared across jurisdictions.

Licence and registration map

• - Hong Kong: check SFC AML/CFT standards, licensed corporation controls, responsible officer/MIC/senior management ownership, and AMLO evidence.
• - UK: check FCA financial crime, SM&CR responsibility, MLRO/compliance ownership, sanctions controls, and monitoring evidence.
• - US: check broker-dealer AML under FINRA/BSA context, adviser compliance evidence, Form ADV/NMA disclosures, and supervisory records.
• - Singapore: check MAS CMS Form 1 evidence, AML/CFT owner, representative model, and business-specific financial-crime controls.
• - Australia: check AFSL compliance, AML/financial crime owner, responsible manager evidence, risk management, and outsourcing controls.

Exam or competence checks

• - AML/CFT role readiness is proved by authority, experience, escalation rights, monitoring files, and testing evidence, not only a certificate.
• - Where the person is also a senior manager, responsible officer, responsible manager, or representative, separate approval or competence evidence may apply.
• - Financial crime training should be tied to the applicant's products, clients, channels, jurisdictions, and transaction patterns.

Application evidence

• - AML/CFT and financial crime risk assessment.
• - CDD, EDD, sanctions, screening, transaction monitoring, suspicious activity, and recordkeeping procedures.
• - Training, independent testing, management information, breach, escalation, and board-reporting calendar.
• - Introducer, placement, private fund, cross-border, politically exposed person, and source-of-funds controls.
• - Outsourced vendor or group AML/CFT service-level, oversight, and exit evidence.

Register checks

• - Check the firm status, permissions, sanctions/warning flags, and disciplinary history on official registers.
• - Check whether named individuals appear on public registers or only internal responsibility maps.
• - Record AML/CFT owner, MLRO, compliance owner, board owner, and outsourced provider responsibilities separately.

Jurisdiction notes

Common mistakes

• - Copying an AML manual without linking it to the applicant's products, clients, countries, payments, and distribution model.
• - Naming an AML/CFT owner who lacks authority, time, escalation access, or evidence of independent testing.
• - Treating sanctions, source-of-funds, private fund investors, introducers, and cross-border onboarding as after-launch details.

Disclaimer

Information on LicenseCompare is for general educational purposes only and does not constitute legal, regulatory, financial, tax, investment, or professional advice. Licensing requirements depend on facts and change over time. Always consult official regulator materials and qualified professional advisers.