The AMLCO Annual Report

The Anti-Money Laundering Compliance Officer’s (AMLCO) Annual Report constitutes a reporting obligation for regulated entities that provide investment, crypto-asset, and payment services. In a nutshell, the report examines matters of compliance for the prevention of money laundering and terrorism financing for the previous year.

In this blog post, the team at the Institute aims to inform you about the preparation and submission of the report and discuss the importance of a complete executive summary. 

At the bottom of the blog, we conclude with an outline of the information provided and the skills gained after the successful completion of the course titled – How to prepare the AMLCO Annual Report.

 
Preparation & Submission

For entities supervised by the Cyprus Securities and Exchange Commission (CySEC) and the Central Bank of Cyprus (CBC), the person responsible for the preparation of the report is the AMLCO. The AMLCO prepares the report during the first two months of each calendar year, following regulatory standards regarding its content. The report references the findings of the previous year on specific matters about the firm’s policies and procedures on anti-money laundering (AML).

By the end of February, the report is submitted to the Board of Directors (BoD) for their review and approval. All matters raised must be discussed and formal minutes must be recorded indicating the specific actions decided, as well as the implementation timeframes. The AMLCO Annual Report must be submitted to the regulator within 20 days of the BoD meeting and the latest by the end of March. The submission of the report must be accompanied by the BoD signed minutes.

Executive Summary

The executive summary is an integral part of the AMLCO Annual Report and must satisfy specific requirements regarding its length and structure. It shall be able to stand as a separate document, outlining the most significant findings and recommendations of the AMLCO during the period examined.

Within the executive summary, the AMLCO explains the purpose of the report and provides the AML objectives defined by the Company. Furthermore, it is important for the AMLCO to briefly describe the inspection methodology followed and the tests performed. The AMLCO signs the report at the end of the executive summary, after presenting final thoughts and key takeaways from the previous year.

What is the AMLCO Annual Report course and what does it include?

The AMLCO Annual Report course has been developed by SALVUS Funds and is delivered by their Risk & Compliance Director, Evdokia Pitsillidou. The course guides employees tasked with AML duties and responsibilities on how to prepare the AMLCO Annual Report for the year 2023 and provides them with all the information to be included. Furthermore, it facilitates BoD members in reviewing and approving the report before its submission to the regulator. The Regulatory Compliance team at SALVUS has accumulated vast experience in preparing annual reports for its clients that are regulated entities offering investment, crypto and payment services. This first-hand experience in preparing the AMLCO report is distilled into this course.

Completing this course provides you with a detailed skeleton of the report, ready to be adjusted to your company’s AML policies and procedures. Additionally, it informs you of common weaknesses identified by the regulator in AMLCO reports submitted in previous years.

The syllabus of the AMLCO Annual Report course includes:

• Introduction of how to prepare the AMLCO Annual Report in 2023
  - Obligation, Purpose & Significance
  - Timeline & Reference period
  - Submission to the Board of Directors
  - Board of Directors minutes
  - Submission to CySEC
  - Contents of the Report
• CySEC Circular C516 - Findings of the AMLCO Annual Reports' Assessment
  - Obligation, Purpose & Significance
     a. Weaknesses
     b. Reminders
  - Reporting tips
• The AMLCO Annual Report; Executive Summary
  - Characteristics
  - Structure
  - Findings & Recommendations
• The AMLCO Annual Report; Company Information, Regulatory Framework & the AML Department
  - The Company- Regulatory Framework
  - The AML Department