Role Tracks: AML Role & Authority Matrix

Operational separation of competence, permitted actions, mandatory escalation, outputs and decision authority.

Role tracks separate competence, permitted actions, escalation duties, outputs and final decision authority. They do not delegate legal responsibility or replace training requirements.

Authority rule: capability does not equal authority. An analyst or AML practitioner may collect evidence, test consistency and draft a recommendation, but final acceptance, reporting, sanctions and exit decisions remain with the role authorised by law and internal governance.

Role and authority overview#

RolePrimary responsibilityDecision boundary
Junior AML AnalystData collection, basic screening, file hygiene and identification of missing informationNo final customer-risk, sanctions or suspicion decision
AML / KYC PractitionerCDD/KYB analysis, UBO mapping, risk-factor assessment and evidence-pack preparationEscalates high risk, unresolved ownership, PEP, sanctions and suspicion indicators
Senior AML Analyst / ReviewerComplex-case review, EDD, quality control and recommendation approval within delegated authorityDoes not replace MLRO, sanctions counsel or senior-management approvals
Compliance Officer / Deputy MLROProgramme governance, policy interpretation, QA, remediation and delegated escalation managementActs only within documented delegation and jurisdiction-specific authority
MLRO / Nominated OfficerSuspicion, reporting, high-risk governance and accountable escalation decisionsLegal, board, sanctions or business approvals remain separate where required

Junior AML Analyst#

Must understandAML/CFT/CPF vocabulary; CDD/KYC inputs; identity and verification basics; PEP, sanctions and adverse-media screening; red flags; evidence provenance.
May performCollect and organise data; run approved searches; capture dated evidence; identify missing information; prepare factual screening notes.
Must escalatePotential sanctions match; PEP or close-associate indicator; material adverse media; inconsistent identity or ownership; unexplained activity; any suspicion indicator.
OutputsMissing-information list; source log; initial screening note; factual red-flag list; escalation record.
Decision authorityNo final risk acceptance, alert closure, EDD waiver, sanctions disposition or SAR/STR decision.

AML / KYC Practitioner#

Must understandCDD, SDD and EDD; beneficial ownership and control; source of funds/wealth; geographic and sector risk; false-positive handling; case narrative and evidence weighting.
May performBuild CDD/KYB files; map UBOs; assess risk factors; resolve routine screening false positives; request information; draft EDD recommendations.
Must escalateUnresolved ownership/control; high-risk PEP; sanctions ownership/control issue; serious adverse media; unexplained source of wealth/funds; suspicion threshold concern.
OutputsCDD summary; UBO map; risk-factor table; evidence pack; information request; EDD recommendation.
Decision authorityRoutine decisions only where expressly delegated; no MLRO reporting decision or legal sanctions conclusion.

Senior AML Analyst / Reviewer#

Must understandComplex structures; PEP family/associates; sanctions ownership/control; advanced EDD; transaction-monitoring rationale; QA and periodic review; sector typologies.
May performReview complex cases; challenge evidence; approve work within delegated limits; calibrate controls; conduct QA; formulate escalation recommendations.
Must escalatePossible legal or sanctions prohibition; material suspicion; risk outside appetite; policy exception; customer exit; unresolved high-risk relationship.
OutputsEDD/PEP/sanctions/adverse-media memo; QA comments; risk recommendation; structured MLRO referral.
Decision authorityLimited to written delegation; cannot assume statutory MLRO, legal, board or senior-management authority.

Compliance Officer / Deputy MLRO#

Must understandAML programme governance; risk appetite; customer acceptance; policies and controls; management information; training governance; audit and inspection readiness.
May performInterpret policy; oversee QA; approve delegated exceptions; manage remediation; coordinate audits; act for MLRO only within documented delegation.
Must escalateMaterial control failure; systemic QA issue; regulatory breach; significant policy exception; board-level risk; matter outside delegated authority.
OutputsControl-gap analysis; exception recommendation; QA trend report; remediation plan; governance and regulatory-response pack.
Decision authorityDefined by governance documents, local law and formal delegation; “Deputy MLRO” is not unlimited authority.

MLRO / Nominated Officer#

Must understandSuspicion and reporting standards; tipping-off; sanctions escalation; customer exit; regulator communication; board reporting; jurisdiction-specific accountability.
May performAssess internal referrals; determine external-reporting action within authority; set escalation outcomes; require remediation; provide accountable governance decisions.
Must escalateMatters requiring legal advice, sanctions specialist action, board approval, law-enforcement engagement, licence application or business-risk acceptance outside MLRO authority.
OutputsDocumented escalation decision; reporting rationale; customer restriction/exit recommendation; board AML input; regulator-response pack.
Decision authorityHigh but jurisdiction-specific. The role does not absorb legal counsel, sanctions authority, board or business ownership of risk.

Practitioner decision-boundary model#

An AML practitioner acts within authority assigned by law, role description, policy and formal delegation. A well-supported recommendation does not become an approval merely because it is complete or persuasive.

  • Material actions should identify the acting role and reviewer.
  • Decision gates are explicit and non-bypassable.
  • Jurisdiction overlays can narrow permissions.
  • Legal, sanctions and MLRO gates remain separate.
  • Reviewer override is recorded with rationale and timestamp.

See Also#

References#