January 12, 2026
3 min read
AML/CFT Compliance Officer and MLRO are often confused — and sometimes combined — but they serve different purposes in a strong compliance framework. This article explains how the AML/CFT Officer focuses on building and overseeing risk-based controls, testing, and board reporting, while the MLRO is responsible for SAR decisions and the reporting process. It also covers when roles can be combined, why seniority matters, and why appointing a Deputy MLRO is considered best practice.

The MLRO and AML/CFT officer positions are not interchangeable, despite what many people would think. In actuality, several companies would frequently combine these roles. Even if a person takes on both responsibilities, it is crucial to recognize how crucial it is to keep these jobs distinct for efficient governance and compliance. We discuss the differences between the roles of an AML/CFT officer and an MLRO in this article.
All licensed gaming businesses are required by law to designate a Money Laundering Reporting Officer, even if they are not yet in business.
Indeed, even if they are not actively trading, all licensed operators are required to employ an AML/CFT Compliance Officer. A professional AML/CFT qualification is not necessary for an AML/CFT Compliance Officer, but they must fulfill the GSC's standards to show that they are knowledgeable about financial crime.
The AML/CFT Officer is a relatively new idea that gives businesses the chance to divide the compliance burden among financial crime specialists, whereas the MLRO function has been around for a number of years.The MLRO's ability to perform both jobs is typically determined by the operator's size and complexity.
The main distinction is that an AML/CFT Compliance Officer is in charge of implementing risk-based AML/CFT procedures in accordance with the AML/CFT Code, monitoring performance, addressing issues, and reporting to the operator's board. In contrast, an MLRO is in charge of the SAR reporting process and handling of SARs, while an AML/CFT Compliance Officer is in charge of making sure that all Code requirements are met, tested, and reported to senior management.
The Code stipulates that the MLRO must have adequate seniority and authority because the MLRO's role is ultimately complicated and necessitates a solid technical grasp of the reporting requirements of the Code as well as important aspects of POCA and ATCA, such as the various disclosures and "consent." An MLRO should be a powerful managerial position with the time and resources to carry out their duties.
In addition to the aforementioned two positions, it is also possible to designate a Deputy MLRO, which is highly advised as best practice. The appointment of the DMLRO guarantees a continuity of service regarding SAR reporting in the event that the designated MLRO is unavailable due to leave or absence, in addition to the DMLRO's ability to assist the MLRO in their tasks.
Anyone employed in the regulated industry should be aware of the distinctions between the two positions. You should understand the responsibilities of each role if you are the employee being asked to perform the role or roles. In a similar vein, it's critical to comprehend the responsibilities of each function if you're searching for someone to fill them. It might not be possible for one individual to do both responsibilities, depending on the type, size, and complexity of your company.
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