Considering the highly regulated nature of the investment fund industry, it is essential that investment funds are confident that their AML officers possess the appropriate knowledge, experience and qualifications that are necessary to discharge their obligations. Constantly evolving legislation equates to a constantly changing AML landscape, which places even greater importance on the role of the AML officer and their ability to succeed in their roles.

Therefore, an investment fund’s governing body must ensure that their decision making process not only ensures that their fund complies with AML legislation, but that it is also capable of withstanding regulatory scrutiny should an issue arise, or during a regulatory inspection. It is also important to note that the decision making relates to the choice of individual, not the choice of the organisation who is subsequently contracted to provide them. 

The Russia Sanctions 2023 concluded greater emphasis on the role of the AML Officer

The implementation of The Russia Sanctions (the “Sanctions”) during 2023 placed increased focus on the knowledge and experience of investment fund AML officers, with fund operators and governing bodies all seeking guidance on how best to deal with exposure to sanctions restrictions. The AML officer, as the person responsible for the investment fund’s AML program was very much front and centre. The Sanctions were a timely reminder that governing bodies must ensure that their AML officers have implemented appropriate AML controls and are able to provide advice from a position of authority when asked to do so. 

Centralis Group’s AML officers are the principle point of contact for investment fund operators and governing bodies and as such are responsible for the implementation of AML/CFT and sanctions risk mitigation controls, including the management of AML, CTF and sanctions issues should they arise. Being physically present in the Cayman Islands and Ireland affords in-depth knowledge of jurisdictional obligations which includes the reporting of suspicious activity and sanctions violations. Any differences in AML standards or reporting obligations are quickly identified and addressed.

Does your AML Officer possess the appropriate skills and expertise?

Regulatory guidance requires that AML officers are:

• Skilled and experienced
• Knowledgeable of the jurisdiction’s legal and regulatory AML framework
• Able to perform their functions independently and autonomously
• Sufficiently senior, with authority that a governing body will react to and act upon
• In regular contact with a governing body/board of directors
• Able to dedicate sufficient time and resources to discharge their obligations
• The main point of contact with supervisory and other competent authorities

Global sanctions restrictions, suspicious activity and investor due diligence concerns are all ongoing challenges for investment funds therefore it is vital that the AML officers, and not a junior member of a broader team, are on hand to deal with them. The Centralis Group AML professionals are best in class. They are individuals who have many years of experience acting in AML officer roles and as such have extensive knowledge of all related AML legislation, providing them the ability to manage an investment fund’s AML obligations professionally and efficiently. The team are highly responsive and the investment fund’s main point of contact. This ensures that any AML, CFT or sanctions related issues are investigated and addressed promptly and efficiently.

Contact Gary McLean (Gary.Mclean@centralisgroup.com) and Brian Kinsella (Brian.Kinsella@centralisgroup.com) to find out how Centralis Group can support your AML function.