Compliance today is not as simple as it used to be. As regulations grow more complex, understanding the difference between a Compliance Officer, a Money Laundering Reporting Officer (MLRO), and a Chief Compliance Officer (CCO) is essential for effective governance, accurate regulatory reporting, and strong risk management.
Compliance Officer, MLRO, and CCO roles are often confused or incorrectly combined and organisations might face higher regulatory risk, weaker controls, and a greater likelihood of enforcement actions if not properly identify each role accordingly. Clear separation of a Compliance Officer, MLRO, and CCO roles strengthens compliance frameworks, improves regulatory confidence, and supports long-term organisational resilience.
There is a common belief that one individual can manage all compliance-related responsibilities, but in practice, this approach rarely works:
- A Compliance Officer helps businesses to comply with laws, regulations, and internal procedures.
- A MLRO focuses on designing and maintaining businesses’ AML compliance framework.
- A CCO oversees and manages compliance across an organisation.
Understanding differences between a Compliance Officer, MLRO, and CCO is critical when ensuring regulatory compliance, operational efficiency, and clear career paths.
Compliance Officer: Day-to-Day Regulatory Compliance.
A Compliance Officer is a professional responsible for ensuring that an organisation operates in line with applicable laws, regulations, regulatory guidelines, and internal policies. In practice, the Compliance Officer acts as a bridge between businesses and regulators.
5 Key Responsibilities of a Compliance Officer.
- Monitoring compliance with local and international regulations
- Identifying compliance gaps and control weaknesses
- Supporting regulatory reporting and examinations
- Coordinating responses to regulatory inquiries
- Delivering compliance training across the organisation
A Compliance Officer operates across departments, including legal, risk, audit, HR, and IT, ensuring compliance requirements are integrated throughout the business.
Who is a Money Laundering Reporting Officer (MLRO)?
A Money Laundering Reporting Officer (MLRO) is the senior individual responsible for an organisation’s anti-money laundering and counter-terrorist financing (AML/CFT) framework. MLRO’s role focuses on identifying, assessing, and managing money laundering and terrorist financing risks, and ensuring the organisation meets its legal and regulatory obligations.
Under UK’s Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (Regulation 21), regulated businesses are required by statute to appoint a MLRO as the nominated officer responsible for receiving and assessing internal reports of suspicious activity and deciding whether to submit them to the National Crime Agency.
4 Core Responsibilities of an MLRO.
- AML Compliance Supervision: MLRO makes sure organizations follow the AML/CFT compliance framework and related AML rules.
- Ensuring effective customer due diligence (CDD): MLRO ensures strong CDD by checking clients’ identities, verifying their information, and monitoring them continuously.
- AML records, risk assessments, and AML training: MLRO ensures all AML-related records, including AML training, risk assessments, and SARs, are maintained in accordance with regulatory requirements.
- Suspicious Activity Reports (SARs): MLRO oversees the monitoring of transactions to detect unusual or suspicious activities. This includes reviewing automated systems and alerts, and conducting investigations as necessary.
Who is a Chief Compliance Officer (CCO)?
A Chief Compliance Officer (CCO) is the senior executive responsible for leading, overseeing, and governing the organisation’s entire compliance function. CCO ensures compliance is integrated into business strategy, not treated as a standalone control function.
5 Key responsibilities of a Chief Compliance Officer (CCO).
- CCO maintains an effective compliance management system
- Leads enterprise-wide compliance risk assessments
- Provides strategic advice to the board and senior leadership
- Oversees regulatory change and implementation across the organisation
- Establishes and promotes standards for ethics, conduct, and governance.
Chief Compliance Officer provides strategic oversight across all compliance functions, including AML, data protection, market conduct, and industry-specific regulations.
Compliance Career Path: From Compliance Officer to MLRO to CCO.
Most compliance careers begin with a Compliance Officer role, where professionals build a strong foundation in regulatory requirements, daily compliance monitoring, reporting obligations, and risk-based controls. With experience, many Compliance Officers specialise in areas such as AML, sanctions, or financial crime, developing deeper expertise and preparing for senior responsibilities.
A MLRO role represents a step into senior compliance leadership, carrying statutory responsibility for AML oversight and suspicious activity reporting. This position requires independence, strong regulatory judgement, and regular engagement with senior management and regulators.
At executive level, CCO provides organisation-wide compliance oversight, leading strategy, governance, and risk management. CCO ensures compliance is integrated into business decisions and supported at board level.
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Conclusion
Strong compliance frameworks depend on clear accountability. Understanding the distinct roles of a Compliance Officer, MLRO, and CCO helps organisations meet regulatory expectations, reduce enforcement risk, and build trust with regulators and stakeholders. Clear role definitions do more than satisfy regulators, these roles protect institutions, strengthen governance, and support sustainable growth.
Contributor: Ms. Ifeoluwa Ademola
