Compliance Officer, MLRO and Approved Person Requirements in GMC: Legal Advisory

A GFSO licence cannot issue, or be kept, without named individuals holding the Senior Executive Officer, Compliance Officer and Money Laundering Reporting Officer functions, and a small firm rarely has three such people ready on day one. Basnet Law Pte.

Mapping every role to the Controlled Functions, from Senior Executive Officer to Responsible Officer, and advising which combinations the Regulator is likely to accept.

Advising on Approved Person applications and the firm's own fitness and competence enquiries.

Advising on the residence requirement for the SEO, Compliance Officer and MLRO, and on waiver applications where a Compliance Officer or MLRO will sit outside GMC.

Advising on structuring shared Compliance Officer arrangements and group-hub outsourcing so the firm stays within the outsourcing rules.

Advising the appointed officers on their legal obligations: compliance manual, monitoring programme, AML manual, whistleblowing policy and training records.

Advising on changes: extensions of approval, temporary cover, withdrawal requests and replacement appointments within the deadlines.

Licence applicants assembling a first management team before the In-Principle Approval condition on key personnel falls due. Small Licensed Firms, fund managers and advisers that want a proportionate compliance function. International groups placing a hub executive over a GMC subsidiary or running due diligence from abroad. Existing Licensed Firms replacing a Compliance Officer or MLRO at short notice.