The role label, legal framework and exact duties change by jurisdiction.
For relevant Luxembourg structures, an external RC can support day-to-day AML/CFT control on behalf of the RR and board. The mandate may cover framework oversight, risk assessment, provider oversight, monitoring, board reporting and escalation.
In Ireland, we can provide a named MLRO for eligible entities. Responsibilities may include oversight of the AML/CFT framework, business-wide risk assessment, policy management, administrator oversight, board reporting and training.
For eligible Cayman structures, we can provide named individuals for the AMLCO, MLRO and DMLRO roles, covering framework oversight and the investigation, escalation and reporting of suspicious activity within scope.
ONE provides relevant RC support in Luxembourg, MLRO services in Ireland and AMLCO, MLRO and DMLRO coverage for eligible Cayman structures. This proposition does not include a UK named MLRO or equivalent named-officer mandate.
Appointing an external officer does not transfer every AML obligation or operational task. A ONE officer will have responsibility and oversight of the AML/CFT framework, reporting periodically to the Board of Directors. This includes oversight of the appointed fund administrator responsible for investor onboarding and, in some cases, oversight of the portfolio manager's investment due diligence process.
Investor onboarding and collection of due diligence may remain with the transfer agent. Asset selection and commercial decisions remain with the portfolio manager and governing body. Fund accounting and servicing remain with the administrator, while depositary duties remain with the depositary. Exact responsibilities depend on the entity, jurisdiction, contracts and agreed mandate.
Appointment depends on eligibility, due diligence, access to information and a documented operating model.
Confirm the entity, jurisdiction, role and relevant eligibility or governance requirements.
Set responsibilities, information rights, provider interfaces, board reporting, escalation and matters retained by the governing body.
Complete due diligence, contracting, appointment and handover, then establish the risk-based annual activity calendar.
Provide monitoring, reporting, training and escalation at the agreed cadence, with scope reviewed as the structure evolves.
A named AML role carries defined responsibilities, judgement and escalation duties. Boards need an officer who understands the applicable regime, has access to information and can demonstrate how oversight is exercised. The appointment must fit the wider operating model, including work performed by administrators, transfer agents, portfolio managers and other delegates.
We provide eligible external appointments in specific jurisdictions, supported by a wider compliance team and consistent delivery methodology. The mandate, reporting cadence, information rights, provider interfaces and matters reserved for the board are documented at the outset.
The service is designed for boards and regulated structures that need local role expertise without creating a full-time position where the workload does not require one. Upon appointment, a framework and reporting mechanism suited to your structure can be discussed.
Holding appointments across multiple funds and working with many service providers gives us a unique view of industry best practices, emerging AML/CFT trends and operational efficiencies, enabling more informed and effective board oversight.
Compare typical responsibilities, retained-provider duties and the appointment process across Luxembourg, Ireland and Cayman.
Tell us which entity, jurisdiction and role you are considering. We will identify the eligibility, scope and mobilisation questions that need to be resolved.
