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AML Compliance Officer Designation & Responsibilities

📅 Updated Dec 2025 ⏱ 35 min read 👤 BSA/AML Compliance

AML Officer Requirements Under the Bank Secrecy Act

Under the Bank Secrecy Act (BSA) and implementing regulations from FinCEN, every Money Services Business (MSB), bank, and certain other financial institutions must designate an individual responsible for day-to-day compliance with AML requirements. This person is commonly called the AML Compliance Officer or BSA Officer.

For trading platforms, cryptocurrency exchanges, payment processors, and fintech companies operating as MSBs, the AML Officer designation is not optional—it's a federal regulatory requirement. The AML Officer serves as the architect and enforcer of your AML program, responsible for preventing money laundering, terrorist financing, and sanctions violations.

⚠ Federal Crime

Operating an MSB without an adequate AML program—including a designated compliance officer—is a federal crime under 18 U.S.C. 1960. FinCEN and DOJ have pursued criminal charges against MSB operators for willful BSA violations, resulting in prison sentences and multi-million dollar penalties.

Legal Basis for AML Officer Requirement

The AML Officer requirement stems from several federal regulations:

For MSBs (the most common designation for trading platforms), the regulation states that the AML program must include, at a minimum:

  1. Written policies, procedures, and internal controls
  2. Designation of a compliance officer
  3. Ongoing employee training program
  4. Independent review/audit function

💡 Crypto Exchange Clarification

FinCEN's 2013 guidance confirmed that administrators and exchangers of convertible virtual currency are money transmitters subject to MSB registration and AML program requirements. This includes cryptocurrency exchanges, OTC desks, DeFi protocols with identifiable operators, and token platforms that exchange crypto for fiat or other crypto.

Qualifications & Experience Requirements

Unlike some regulatory designations (e.g., securities exams for broker-dealer principals), there is no statutory examination or licensing requirement to become an AML Compliance Officer. However, FinCEN and bank regulators expect the AML Officer to have adequate knowledge, experience, and authority to fulfill their responsibilities.

Core Competency Requirements

An effective AML Compliance Officer should possess:

AML Officer Qualifications Matrix

Competency Area Knowledge Requirements Typical Background
BSA/AML Regulations Deep understanding of Bank Secrecy Act, FinCEN regulations, OFAC sanctions, USA PATRIOT Act Prior AML role, compliance training, CAMS/CFCS certification
Suspicious Activity Recognition Ability to identify red flags for money laundering, terrorist financing, fraud Law enforcement, fraud investigation, financial crimes analysis
Industry Knowledge Understanding of your specific business model and associated ML risks Experience in fintech, payments, crypto, or banking sector
Customer Due Diligence KYC procedures, identity verification, enhanced due diligence, risk rating Onboarding operations, fraud prevention, identity verification
Transaction Monitoring Monitoring systems, alert investigation, pattern recognition, case management Compliance monitoring, analytics, investigations
Regulatory Reporting SAR filing, CTR filing, FBAR reporting, recordkeeping requirements Regulatory reporting experience, compliance operations
Technology & Data Compliance technology platforms, data analysis, system controls (for fintech/crypto platforms) Technology background, data science, systems implementation
Training & Communication Ability to train staff, communicate with regulators, brief management Training development, regulatory relations, management reporting

Professional Certifications

While not legally required, professional certifications demonstrate competency and are valued by regulators:

CAMS

Certified Anti-Money Laundering Specialist

  • Issuer: ACAMS (Association of Certified Anti-Money Laundering Specialists)
  • Requirements: Pass exam + qualifying experience
  • Cost: $1,495 (members) / $1,795 (non-members)
  • Renewal: Annual dues + 60 CPE credits every 3 years
  • Focus: Broad AML/CFT fundamentals, international scope
  • Best For: General AML compliance officers, especially MSBs and banks
CFCS

Certified Financial Crime Specialist

  • Issuer: ACFCS (Association of Certified Financial Crime Specialists)
  • Requirements: Pass exam (no experience requirement)
  • Cost: $495 exam + $250 annual membership
  • Renewal: 20 CPE credits annually
  • Focus: Financial crimes including fraud, sanctions, cybercrime
  • Best For: Broader financial crimes role beyond just AML
CRCM

Certified Regulatory Compliance Manager

  • Issuer: ABA (American Bankers Association)
  • Requirements: Pass exam + banking experience
  • Cost: $895 (members) / $1,195 (non-members)
  • Renewal: 30 CPE credits every 3 years
  • Focus: Bank regulatory compliance (includes but not limited to AML)
  • Best For: Bank compliance officers with broad responsibilities

✅ Certification Recommendation

For trading platforms and crypto businesses, CAMS is the gold standard. It's the most widely recognized AML certification and demonstrates credible expertise to FinCEN examiners and law enforcement. Budget $2,000-$3,000 for initial certification including exam prep, exam fee, and study materials.

Small Firm vs. Large Firm Experience Expectations

Firm Size/Type Typical AML Officer Profile Minimum Qualifications
Startup MSB (1-10 employees) Founder/CEO or outsourced consultant Basic BSA knowledge, willingness to learn, access to external expertise
Small MSB (10-50 employees) Dedicated compliance staff or part-time officer 1-2 years AML experience or CAMS certification, understanding of MSB regulations
Mid-Size MSB (50-500 employees) Full-time AML/Compliance Officer with support staff 3-5 years AML experience, CAMS preferred, transaction monitoring expertise
Large Platform (500+ employees) Senior AML Officer with team of analysts, investigators, and specialists 7+ years AML experience, CAMS required, management experience, regulatory examination experience
Bank or Financial Institution VP/SVP-level BSA Officer with dedicated BSA/AML department 10+ years banking/AML experience, multiple certifications (CAMS, CRCM), examination management

Key Responsibilities & Duties

The AML Compliance Officer has broad responsibility for the design, implementation, and enforcement of the firm's AML program. Specific duties vary based on firm size and complexity, but the core responsibilities are consistent.

Primary AML Officer Responsibilities

Core AML Officer Duties (25+ Essential Items)

  • Design and implement written AML policies and procedures
  • Maintain and update AML program documentation
  • Oversee customer identification program (CIP/KYC)
  • Develop and maintain customer risk rating methodology
  • Implement enhanced due diligence (EDD) procedures for high-risk customers
  • Design and oversee transaction monitoring systems and processes
  • Review and investigate alerts generated by monitoring systems
  • Conduct investigations of potentially suspicious activity
  • Determine whether to file Suspicious Activity Reports (SARs)
  • Prepare and file SARs with FinCEN within required timeframes
  • File Currency Transaction Reports (CTRs) for cash transactions over $10,000
  • Screen customers and transactions against OFAC sanctions lists
  • Block and report transactions involving sanctioned parties
  • Develop and deliver AML training programs for all employees
  • Maintain training records and ensure annual training completion
  • Conduct risk assessments of the firm's products, services, customers, and geographies
  • Update AML program based on risk assessment findings
  • Coordinate independent testing/audit of AML program
  • Remediate findings from audits and examinations
  • Maintain AML recordkeeping in compliance with 5-year retention requirement
  • Respond to law enforcement inquiries (subpoenas, 314(a) requests)
  • Serve as primary contact for FinCEN examiners
  • Report AML issues and program status to senior management and board
  • Monitor regulatory developments and update program accordingly
  • Oversee vendor relationships for KYC, screening, and monitoring technology
  • Manage relationships with correspondent banks and financial institution partners
  • Document all compliance decisions and maintain audit trail

Day-to-Day Activities Breakdown

Daily Tasks
  • Review transaction monitoring alerts
  • Screen new customer applications against OFAC lists
  • Investigate flagged transactions or customer activity
  • Monitor regulatory news and updates
  • Respond to internal AML inquiries
  • Review high-risk account activity
Weekly Tasks
  • Review escalated cases from monitoring team
  • Quality control review of investigations
  • SAR filing decisions and submissions
  • Management reporting on key metrics
  • Training coordination and scheduling
Monthly Tasks
  • SAR/CTR filing reconciliation
  • AML metrics dashboard review
  • Alert tuning and false positive analysis
  • High-risk customer review
  • Vendor performance assessment
Quarterly Tasks
  • Board/management AML program briefing
  • Risk assessment updates
  • Policy and procedure review
  • Transaction monitoring scenario effectiveness review
  • Employee AML training sessions
Annual Tasks
  • Comprehensive AML risk assessment
  • Independent AML program audit/testing
  • MSB registration renewal with FinCEN
  • Annual training curriculum update
  • AML program annual report to management
  • Lookback reviews and quality control

Authority & Resources Required

For an AML program to be effective, the AML Compliance Officer must have real authority and adequate resources. Regulators scrutinize whether the AML Officer is truly empowered or merely a figurehead.

Independence and Authority

The AML Officer must have:

⚠ Red Flag: Revenue-Based Compensation

The AML Officer's compensation should not be primarily based on revenue generation or business growth. Tying AML compensation to sales creates an impermissible conflict where the officer has financial incentive to approve risky customers or overlook suspicious activity. FinCEN has cited this as a program deficiency.

Resource Requirements

Resource Category Minimum Requirements Scaling Considerations
Staffing At least one designated AML Officer (may be part-time for very small firms) Add investigators, analysts, screening specialists as transaction volume grows
Technology KYC/identity verification tool, OFAC screening system, basic transaction monitoring Advanced monitoring platforms, case management systems, network analysis tools
Data Access Complete transaction history, customer profiles, account activity logs Real-time monitoring feeds, data analytics platforms, external data sources
Training Budget AML training for all staff annually, certification for AML Officer Advanced training, conferences, external subject matter experts
Legal/Consulting Access to BSA/AML counsel for complex matters Ongoing legal support, independent testing firms, specialized consultants
Audit/Testing Annual independent testing of AML program Big Four audit, specialized AML testing firms for complex programs

⚠ Adequacy Standard

Resources must be "commensurate with the size and complexity of the institution and the nature and scope of its activities." A high-volume crypto exchange cannot meet BSA requirements with a single part-time AML officer. FinCEN examinations assess whether resources are adequate for your specific risk profile.

Reporting Structure & Independence

The AML Officer's position in the organizational structure matters. Proper reporting lines ensure the officer has visibility, authority, and the ability to escalate issues without fear of retaliation.

Recommended Reporting Structures

Reporting Structure Pros Cons Best For
Reports to CEO Maximum visibility, direct access to decision-maker, strong authority CEO may lack compliance expertise, potential for business pressure Small to mid-size firms, startups
Reports to CFO/COO Practical for operational issues, financial oversight alignment May be viewed as operational rather than compliance function Mid-size firms with strong finance function
Reports to Chief Compliance Officer Centralized compliance function, specialized expertise Requires adequate resources for CCO function, potential budget conflicts Larger firms with dedicated compliance teams
Reports to Board/Audit Committee Maximum independence, strong governance Less frequent interaction, may slow operational decisions Banks, large financial institutions, public companies
Dual Reporting (Functional & Administrative) Balances independence with operational efficiency Can create confusion about authority, requires clear delineation Large, complex organizations

💡 Functional Independence

While the AML Officer may report to another executive administratively (for HR, budget, etc.), they should have functional independence on AML decisions. This means the AML Officer can make compliance determinations—such as filing a SAR or exiting a customer—without requiring approval from the business side.

Board and Senior Management Oversight

The AML Officer should have regular touchpoints with senior leadership:

Third-Party AML Officer Services

Small firms—particularly startups and early-stage trading platforms—often cannot afford a full-time, experienced AML Compliance Officer. Third-party AML officer services provide an alternative.

Outsourced vs. In-House AML Officer

Factor In-House AML Officer Outsourced AML Officer
Cost $80K-$200K+ annually (salary + benefits) $2K-$10K monthly retainer (depends on scope)
Availability Full-time, on-site, immediate response Part-time, scheduled check-ins, emergency support
Expertise Develops firm-specific knowledge over time Deep regulatory expertise, broader industry experience
Scalability Must hire additional staff as firm grows Can adjust retainer scope as needs change
Independence Potential internal pressure, organizational conflicts Greater independence, external perspective
Regulatory Acceptance Fully acceptable to regulators Acceptable if provider is qualified and engaged
Knowledge Retention Institutional knowledge stays with firm Risk of knowledge loss if provider changes
Day-to-Day Operations Handles daily monitoring, investigations, decisions Firm staff typically handle daily tasks with officer oversight

When to Use Third-Party AML Officer Services

Outsourced AML Officers work best for:

⚠ Transition Planning

Most firms should view outsourced AML officers as a temporary solution. As transaction volume and complexity grow, an in-house AML officer becomes necessary. Plan to transition from outsourced to in-house once you reach $10M+ in revenue or 10,000+ active customers.

What to Look for in a Third-Party AML Provider

Third-Party AML Officer Vendor Evaluation Checklist

  • CAMS or equivalent professional certification
  • 5+ years hands-on AML compliance experience
  • Experience with your specific industry (fintech, crypto, payments, etc.)
  • Knowledge of FinCEN examination process and expectations
  • References from current or former MSB clients
  • Clear scope of services (what they do vs. what you must do internally)
  • Technology platform compatibility (can work with your systems)
  • Response time commitments (how quickly they respond to urgent issues)
  • Defined escalation procedures for suspicious activity
  • Professional liability insurance (E&O coverage)
  • No conflicts of interest with your business
  • Transparent pricing with defined deliverables

Personal Liability & Protections

AML Compliance Officers face potential personal liability—both civil and criminal—for AML program failures. Understanding these risks and implementing appropriate protections is critical.

Potential Liability Exposures

Type of Liability Legal Basis Potential Consequences Recent Examples
Criminal Prosecution 18 U.S.C. 1956 (money laundering), 1960 (unlicensed MSB), willful BSA violations Prison time, criminal fines, restitution Liberty Reserve ($6B case, founder sentenced to 20 years)
Civil Money Penalties FinCEN enforcement under Bank Secrecy Act Personal fines up to $100,000+ per violation MoneyGram CCO fined $250K personally (2018)
Professional Bar Prohibition from working in financial services Career-ending ban from banking/finance industry Several BSA officers barred from banking by OCC/FDIC
State Licensing Action State money transmitter regulators License revocation, individual accountability New York DFS consent orders naming individual officers
Civil Lawsuits Shareholder derivative suits, victim lawsuits Personal liability for damages, legal defense costs Payday lender AML officers sued by fraud victims
Professional Negligence Breach of duty, negligence claims Damages, loss of professional certifications Compliance consultants sued for inadequate AML programs

⚠ When Can AML Officers Be Criminally Prosecuted?

Criminal liability typically requires willfulness—knowingly and intentionally violating the law or turning a blind eye to obvious red flags. Courts have found willfulness when AML officers: (1) Ignored obvious money laundering, (2) Failed to file required SARs despite knowledge of suspicious activity, (3) Helped customers evade BSA requirements, or (4) Maintained deliberately ineffective programs to allow illegal activity.

Recent AML Officer Enforcement Cases

Understanding actual enforcement cases helps AML Officers assess real-world liability risk:

Case Study 1: MoneyGram International (2018)

Facts: MoneyGram's Chief Compliance Officer was personally fined $250,000 by FinCEN for BSA program failures. The CCO knew that MoneyGram agents were facilitating fraud schemes targeting elderly victims but failed to terminate agent relationships or file adequate SARs.

Liability Basis: Personal civil money penalties for willful violations of BSA program requirements.

Key Takeaway: Even C-suite compliance officers face personal liability when they have knowledge of compliance failures but fail to act. The CCO's argument that senior management overruled compliance decisions was rejected—officers must escalate to the board or resign rather than acquiesce.

Case Study 2: Liberty Reserve (2013)

Facts: Arthur Budovsky, founder and operator of Liberty Reserve digital currency exchange, was convicted of money laundering conspiracy and operating an unlicensed money transmitting business. Liberty Reserve processed $6 billion in transactions with virtually no AML controls. The platform was explicitly designed to facilitate money laundering.

Liability Basis: 18 U.S.C. 1960 (unlicensed MSB), 18 U.S.C. 1956 (money laundering conspiracy).

Sentence: 20 years in federal prison, forfeiture of $122 million.

Key Takeaway: Operating a business model designed to evade AML requirements is criminal. The "we're just a technology platform" defense failed.

Case Study 3: BTC-e / Alexander Vinnik (2017)

Facts: Alexander Vinnik operated BTC-e, a cryptocurrency exchange that processed over $4 billion for criminal enterprises including ransomware operators, darknet marketplaces, and identity thieves. BTC-e maintained minimal KYC and deliberately facilitated laundering.

Liability Basis: Money laundering conspiracy, operating unlicensed money transmitting business.

Penalty: Vinnik indicted; $110 million civil penalty against BTC-e; $12 million personal fine.

Key Takeaway: Cryptocurrency exchanges are not exempt from AML requirements. Operators who knowingly serve criminal clientele face criminal prosecution.

Case Study 4: U.S. Bank (2018) - Compliance Officer Not Personally Charged

Facts: U.S. Bank paid $613 million to settle claims it failed to maintain adequate AML program and filed incomplete SARs. The bank's AML program had systemic deficiencies over multiple years.

Outcome: Despite massive institutional penalties, individual compliance officers were NOT personally charged.

Why Officers Were Protected: Officers documented compliance deficiencies, requested additional resources, and escalated concerns to senior management. When management failed to provide adequate resources, officers maintained contemporaneous documentation showing good-faith efforts within resource constraints.

Key Takeaway: Documenting your efforts, resource requests, and escalations provides significant protection even when the institution's program fails.

Case Study 5: Danske Bank Estonia (2018)

Facts: Danske Bank's Estonia branch processed approximately €200 billion in suspicious transactions from Russia and former Soviet states. Multiple AML officers raised concerns internally, but senior management failed to act.

Outcome: Several senior executives resigned; Danish and Estonian authorities pursued criminal investigations. AML officers who documented escalations and resigned in protest were not charged.

Key Takeaway: When you identify systemic money laundering and management refuses to act, document everything and consider resignation with contemporaneous memo explaining reasons.

When Personal Liability Attaches: Critical Factors

Based on enforcement history, AML Officers face heightened personal liability risk when:

Risk Factor Description Mitigation Strategy
Actual Knowledge of ML You personally know specific transactions or customers are engaged in money laundering File SAR immediately; if management blocks filing, document in writing and escalate to board
Willful Blindness You deliberately avoid learning about obvious red flags ("don't ask, don't tell") Investigate all alerts and escalations thoroughly; document your analysis
Active Facilitation You help customers structure transactions or evade reporting requirements Never coach customers on how to avoid AML controls; report any requests to do so
Sham Programs You implement deliberately ineffective "paper programs" designed to enable illegal activity Ensure your program is designed to actually detect and prevent money laundering, not just check regulatory boxes
Personal Benefit You receive kickbacks, bribes, or performance compensation for approving risky customers Refuse any compensation tied to customer approval or revenue generation; negotiate fixed salary + compliance-based metrics only
Repeated Violations After regulatory warnings or exam findings, you fail to remediate known deficiencies Treat examination findings as urgent priorities; document all remediation efforts with timelines
Lack of Documentation No paper trail showing reasonable compliance efforts or good-faith decision-making Document everything: investigations, SAR decisions, resource requests, escalations

Protections and Risk Mitigation

1. Document Everything

Your best protection is a clear paper trail showing reasonable, good-faith compliance efforts:

2. Obtain Written Authority

Formalize your role with clear documentation:

Sample AML Officer Designation Letter

AML COMPLIANCE OFFICER DESIGNATION

Date: [DATE]
To: [AML Officer Name]
From: [CEO/Board Chair Name and Title]

This letter confirms your designation as Anti-Money Laundering Compliance Officer for [Company Name] ("Company"), effective [DATE].

Authority and Responsibilities:

As AML Compliance Officer, you have full responsibility and authority for the Company's compliance with the Bank Secrecy Act and FinCEN regulations. Your duties include:

1. Designing, implementing, and maintaining the Company's AML program
2. Overseeing customer due diligence and transaction monitoring
3. Making determinations regarding Suspicious Activity Report (SAR) filings
4. Serving as primary contact with FinCEN and regulatory examiners
5. Developing and delivering AML training to all employees
6. Coordinating independent testing of the AML program
7. Reporting AML program status to senior management and the Board

Independence and Resources:

You are authorized to make compliance decisions, including SAR filings and customer relationship terminations, without requiring approval from business units. You have direct access to all customer and transaction data necessary to fulfill your responsibilities. The Company commits to providing adequate staffing, technology, and budget resources to support an effective AML program commensurate with the Company's size and risk profile.

You have a direct reporting line to [CEO/Board] for AML matters and are expected to escalate significant compliance issues immediately.

Indemnification:

To the fullest extent permitted by law, the Company will indemnify and hold you harmless from claims, damages, and expenses (including reasonable attorneys' fees) arising from your performance of AML Officer duties, provided you act in good faith and within the scope of your authority.

Acknowledged and Accepted:

____________________________
[AML Officer Signature and Date]

____________________________
[CEO/Board Chair Signature and Date]

3. Obtain Indemnification and Insurance

4. Know When to Say No (and Document It)

⚠ When to Escalate or Resign

If management overrides your compliance decisions, refuses to provide adequate resources, or directs you to ignore red flags, you have three options: (1) Escalate in writing to the Board, documenting your objections; (2) Resign and document reasons in writing; (3) Consult with legal counsel about potential whistleblower protections. Do NOT stay silent and implement inadequate compliance measures—you can be held personally liable even if following management orders.

5. Maintain Professional Standards

Small Firm vs. Large Firm AML Officers

The AML Officer role varies dramatically based on firm size. Here's how the role differs across organization types:

Aspect Small Firm (under 50 employees) Large Firm (500+ employees)
Staffing Solo officer or 1-2 person compliance team AML department with 10-100+ specialists
Time Allocation Hands-on: personally reviewing alerts, filing SARs, conducting investigations Managerial: overseeing teams, strategic planning, regulatory relations
Technology Basic monitoring tools, spreadsheet tracking, manual processes Enterprise AML platforms, AI/ML monitoring, integrated case management
Typical Salary $60K-$120K $150K-$400K+ (VP/SVP level)
Reporting Directly to CEO/founder To Chief Compliance Officer, Board Risk Committee, or C-suite
Customer Volume Hundreds to low thousands Hundreds of thousands to millions
SAR Volume 5-50 SARs annually 500-5,000+ SARs annually
Training Officer conducts training personally Dedicated training team with LMS platform
Audit/Testing Small consulting firm, annual testing Big Four audit, continuous monitoring, multiple audits
Other Duties Often combined with privacy, fraud, general compliance AML-focused, may have separate fraud/sanctions/KYC teams

💡 Career Path Consideration

Many AML professionals start at large banks or established MSBs to gain experience with enterprise systems and processes, then move to smaller fintech firms for broader responsibility and equity upside. Alternatively, start at a fintech startup, gain CAMS certification, then move to larger institution for higher compensation.

Training & Certification Programs

Ongoing training is essential for AML Officers to stay current with evolving regulations, emerging typologies, and enforcement trends.

Initial Training for New AML Officers

AML Officer Onboarding Training Curriculum (First 90 Days)

  • Bank Secrecy Act fundamentals and legislative history
  • FinCEN regulations applicable to your business type (MSB, bank, etc.)
  • Customer Identification Program (CIP) and Know Your Customer (KYC) requirements
  • Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) standards
  • Beneficial ownership identification (FinCEN Customer Due Diligence Rule)
  • Transaction monitoring methodologies and red flags
  • Suspicious Activity Report (SAR) filing requirements and procedures
  • Currency Transaction Report (CTR) filing requirements
  • OFAC sanctions programs and screening requirements
  • USA PATRIOT Act provisions (Section 311, 312, 313, 314, 326)
  • Recordkeeping requirements (5-year rule)
  • Independent testing/audit expectations
  • Your firm's specific AML policies and procedures
  • Your firm's technology systems and tools
  • Industry-specific money laundering typologies (crypto, payments, etc.)
  • Recent FinCEN enforcement actions and trends

Continuing Education Requirements

Professional certifications require ongoing continuing education:

Certification CPE Requirement Reporting Period Acceptable Activities
CAMS 60 credits Every 3 years Conferences, webinars, self-study courses, writing, teaching, ACAMS events
CFCS 20 credits Annually ACFCS events, industry conferences, online courses, compliance activities
CRCM 30 credits Every 3 years ABA programs, compliance seminars, regulatory training, self-study

Recommended Training Resources

✅ Annual Training Budget Recommendation

Budget $3,000-$10,000 annually per AML officer for training, including: Certification renewal fees, conference attendance (AML conferences typically $1,500-$3,000), online courses, industry association memberships, and training materials. This is a worthwhile investment for maintaining competency and demonstrating commitment to regulators.

AML Compliance Officer Job Description Template

Below is a comprehensive job description template that can be customized for your organization. This template addresses regulatory expectations while attracting qualified candidates.

AML Compliance Officer - Job Description Template

Position Title: AML Compliance Officer / BSA Officer

Department: Compliance / Legal / Risk

Reports To: Chief Compliance Officer / CEO / Board

FLSA Status: Exempt

POSITION SUMMARY

[Company Name] seeks an experienced AML Compliance Officer to design, implement, and oversee our Bank Secrecy Act (BSA) / Anti-Money Laundering (AML) compliance program. The AML Officer will be responsible for ensuring compliance with all federal and state AML requirements, including FinCEN regulations, OFAC sanctions, and applicable money transmitter laws.

This position serves as the primary regulatory contact for AML matters and has direct responsibility for suspicious activity monitoring, investigations, regulatory reporting, and program effectiveness.

ESSENTIAL DUTIES AND RESPONSIBILITIES

Program Management (40%)

  • Design, implement, and maintain comprehensive written AML policies and procedures
  • Conduct annual AML risk assessments covering products, customers, geographies, and delivery channels
  • Develop and update internal controls to mitigate identified money laundering risks
  • Coordinate independent testing/audit of AML program and remediate findings
  • Report AML program status, metrics, and issues to senior management and board quarterly
  • Monitor regulatory developments and update program for new requirements

Transaction Monitoring & Investigations (30%)

  • Oversee daily transaction monitoring operations and alert investigation
  • Review escalated alerts and conduct complex investigations
  • Identify patterns indicative of money laundering, fraud, or terrorist financing
  • Make final determination on Suspicious Activity Report (SAR) filing decisions
  • Prepare and file SARs with FinCEN within required 30-day timeframe
  • Maintain SAR documentation and confidentiality

Customer Due Diligence (15%)

  • Oversee Customer Identification Program (CIP/KYC) implementation
  • Develop Enhanced Due Diligence (EDD) procedures for high-risk customers
  • Review and approve high-risk customer onboarding
  • Conduct periodic reviews of existing customer risk ratings
  • Implement beneficial ownership identification procedures

Regulatory Compliance & Reporting (10%)

  • Screen customers and transactions against OFAC sanctions lists daily
  • File Currency Transaction Reports (CTRs) for transactions over $10,000
  • Respond to law enforcement requests (grand jury subpoenas, 314(a) requests)
  • Serve as primary contact for FinCEN and IRS examinations
  • Maintain MSB registration and state money transmitter license compliance

Training & Communication (5%)

  • Develop and deliver annual AML training for all employees
  • Create role-specific training curricula for high-risk positions
  • Maintain training attendance records and assess effectiveness
  • Communicate AML program updates and regulatory changes to staff

REQUIRED QUALIFICATIONS

Education:

  • Bachelor's degree in Finance, Business, Criminal Justice, or related field (required)
  • CAMS (Certified Anti-Money Laundering Specialist) certification (strongly preferred)
  • JD or advanced degree in compliance, risk management, or related field (preferred)

Experience:

  • Minimum 3-5 years of hands-on BSA/AML compliance experience
  • Experience in fintech, cryptocurrency, payments, or money services business (preferred)
  • Direct experience filing SARs and conducting AML investigations
  • Transaction monitoring system experience (rules-based or AI/ML platforms)
  • FinCEN examination or regulatory audit experience (preferred)

Knowledge & Skills:

  • Deep knowledge of Bank Secrecy Act, USA PATRIOT Act, and FinCEN regulations
  • Understanding of OFAC sanctions programs and screening requirements
  • Familiarity with money laundering typologies and red flags
  • Strong analytical and investigative skills
  • Excellent written and verbal communication skills
  • Ability to work independently and make sound compliance judgments
  • Proficiency with compliance technology platforms and data analysis tools
  • Project management and organizational skills

PREFERRED QUALIFICATIONS

  • Cryptocurrency/blockchain AML experience (for crypto platforms)
  • Blockchain analytics tools experience (Chainalysis, Elliptic, TRM Labs)
  • Travel Rule implementation experience
  • Experience with state money transmitter licensing and compliance
  • Prior law enforcement, financial crimes investigation, or fraud prevention background
  • Multiple professional certifications (CAMS, CFCS, CRCM)

PHYSICAL DEMANDS AND WORK ENVIRONMENT

  • Primarily office-based or remote work environment
  • Extended computer use and screen time
  • Occasional travel for training, conferences, or examinations (10-20%)
  • Availability for urgent compliance matters outside normal business hours

COMPENSATION RANGE

[See market compensation data below - typically $80K-$200K+ depending on firm size and location]

EQUAL OPPORTUNITY STATEMENT

[Company Name] is an equal opportunity employer committed to diversity and inclusion.

Compensation & Job Market Analysis

AML Compliance Officer compensation varies significantly based on firm size, location, industry, and experience level. Understanding market rates is essential for both employers hiring talent and professionals negotiating compensation.

2025 Salary Benchmarks by Firm Size

Firm Size / Type Base Salary Range Bonus/Incentive Total Compensation Equity (Startups)
Early-Stage Startup (<$5M rev) $80K-$120K 0-10% bonus $80K-$132K 0.25-1.0% equity
Growth-Stage Startup ($5M-$50M rev) $100K-$150K 10-20% bonus $110K-$180K 0.1-0.5% equity
Mid-Size MSB ($50M-$500M rev) $120K-$180K 15-25% bonus $138K-$225K Varies (if pre-IPO)
Large Fintech/Crypto Exchange (>$500M rev) $150K-$250K 20-40% bonus $180K-$350K RSUs if public
Regional Bank (VP level) $110K-$160K 10-20% bonus $121K-$192K N/A
Large Bank (VP-SVP level) $140K-$220K 20-30% bonus $168K-$286K N/A
Money Center Bank (SVP-EVP level) $200K-$400K+ 30-50% bonus $260K-$600K+ Stock awards

Geographic Salary Adjustments (% of Base)

Location Adjustment Factor Typical Range (Mid-level)
San Francisco / Silicon Valley +30-40% $156K-$252K
New York City +25-35% $150K-$243K
Los Angeles / Seattle +15-25% $138K-$225K
Boston / Washington DC +10-20% $132K-$216K
Chicago / Denver / Austin +5-15% $126K-$207K
National Average (Baseline) 0% $120K-$180K
Secondary Markets -10-20% $96K-$162K
Remote (No Geographic Premium) -15-25% $90K-$153K

Experience Level Progression

Experience Level Years Typical Title Salary Range
Entry-Level AML Analyst 0-2 years AML Analyst, BSA Analyst $50K-$75K
Junior AML Officer 2-4 years Senior AML Analyst, Assistant AML Officer $70K-$100K
AML Compliance Officer 4-7 years AML Officer, BSA Officer, Compliance Manager $100K-$150K
Senior AML Officer 7-10 years Senior AML Officer, Director of AML Compliance $140K-$200K
AML Leadership 10+ years VP/SVP AML, Head of AML, Chief AML Officer $180K-$400K+

Job Market Demand & Trends

High Demand Market

AML Compliance Officers are in strong demand as of 2025. Key trends driving demand:

  • Fintech Growth: Explosion of fintech startups, neobanks, and payment platforms requiring MSB registration and AML programs
  • Crypto Regulation: Regulatory crackdown on cryptocurrency exchanges creating urgent need for qualified crypto AML officers
  • Regulatory Intensity: Increased FinCEN enforcement and examination frequency driving investment in compliance
  • Talent Shortage: Limited supply of experienced AML professionals with crypto/fintech expertise
  • Remote Opportunities: Shift to remote work expanding geographic opportunities for AML talent

Benefits & Perks Beyond Base Salary

Third-Party AML Officer Consulting Rates

For consultants providing outsourced AML Officer services:

Service Model Pricing Structure Typical Client
Monthly Retainer (Part-Time) $2,000-$5,000/month Startup MSBs, low transaction volume
Monthly Retainer (Full Service) $5,000-$15,000/month Growing MSBs, moderate complexity
Hourly Consulting $200-$500/hour Project-based, audit remediation
Per-SAR Pricing $500-$1,500 per SAR prepared Small firms with infrequent SARs
Transaction Volume-Based $X per 1,000 transactions High-volume, low-risk platforms

AML Officer Designation Requirements

The AML Officer designation must be formalized and communicated to regulators and internal stakeholders.

Formal Designation Process

  1. Board/Management Approval: Board resolution or management approval designating the individual as AML Compliance Officer
  2. Written Designation Letter: Formal letter documenting authority, responsibilities, and resources (see template above)
  3. AML Program Documentation: AML policies and procedures must identify the AML Officer by name and title
  4. Regulatory Notification: AML Officer information included in MSB registration (FinCEN Form 107) if applicable
  5. Internal Communication: Announce designation to all staff so employees know who to contact for AML issues
  6. External Communication: Update website, compliance materials, and bank/partner notifications

MSB Registration Requirements

For Money Services Businesses, you must provide AML Officer information to FinCEN:

⚠ Vacant AML Officer Position

If your AML Officer resigns or is terminated, you must fill the position promptly. Operating without a designated AML Officer—even temporarily—is a BSA violation. If there's a gap, designate an interim officer immediately (CEO or senior manager) and begin search for permanent replacement.

Change of AML Officer Procedures

AML Officer Transition Checklist

  • Conduct exit interview with departing officer to document program status and pending issues
  • Designate interim AML Officer if permanent replacement not immediately available
  • Transition knowledge: review cases, investigations, pending SARs, risk assessments
  • Transfer system access and credentials
  • Update AML policies to reflect new officer name and contact information
  • File amended MSB registration (if applicable) within 180 days
  • Notify board/senior management of transition
  • Communicate internally to staff
  • Notify banks, correspondent institutions, and key partners
  • Update website and external compliance materials
  • Ensure new officer receives comprehensive onboarding and training
  • Schedule independent testing to assess program during transition period
Disclaimer: This guide provides general educational information about AML Compliance Officer requirements for trading platforms and financial services firms. It is not legal advice and does not create an attorney-client relationship. AML regulations are complex and fact-specific. Consult with qualified BSA/AML legal counsel and compliance professionals to ensure your AML program and officer designation meet all applicable requirements for your specific business model and risk profile.