AML duties cannot be fulfilled on the side. The law therefore requires someone in the business to be responsible. For FINMA-supervised institutions the FINMA Anti-Money Laundering Ordinance calls this function the AML unit; day to day it is the AML compliance officer. The regulations of the self-regulatory organisations require a comparable responsible person.
Tasks
The unit prepares and updates internal directives, plans and delivers training, supports staff with clarifications, monitors compliance with the due diligence duties and is the contact for supervisors and auditors. Depending on the organisation it decides on reports to MROS or prepares those decisions for management.
Distinction from management
Responsibility for compliance stays with the highest governing body. The unit supports and monitors; it does not replace that responsibility. This matters when business interests and compliance collide: the unit needs access to all information and must be able to raise concerns directly with management.
Organisation in small institutions
In a small family office or fiduciary boutique the unit is often one person with other tasks. That is permitted but requires a clear deputy, documented training and separation where the person runs their own mandates. Some institutions outsource parts of the function to specialised providers; responsibility remains internal. For newly covered advisers, appointing this person is among the first steps of SRO membership.