When do you need an AML specialist and what do they do?

Complying with anti-money laundering regulations is business-critical for organisations subject to the AML regulatory framework. Depending on your set-up, routines alone may not always be sufficient to understand and manage money laundering risks—this is where the AML specialist comes in.

An AML specialist dives deeply into your business flows and structures. This may involve conducting AML investigations into suspicious transactions or activities, carrying out beneficial owner identification (including UBO identification of the ultimate beneficial owner), or analysing complex transactional patterns. The role is often in-house, but in smaller organisations or for specific matters, the specialist is engaged as an external expert. In practice, this blends analytical work with business structure analysis and hands-on AML risk management within the wider AML compliance consulting context.

The difference between the CFA and an external specialist in AML compliance consulting

The Centrally Responsible Function Holder (CFA) carries extensive and formal responsibility under the Anti-Money Laundering Act and the Swedish Financial Supervisory Authority (FI)’s regulations. This includes:

• Monitor compliance: Oversee and verify that the business complies with money laundering regulations, applicable provisions and internal policies.
• Support the organisation: Provide advice and support to employees and other stakeholders across the company.
• Training: Take responsibility for information and training on anti money laundering regulations.
• Review routines: Assess that routines are appropriate and effective under Chapter 2, Sections 8–12 of the Anti-Money Laundering Act and Chapter 2, Section 2 of the Swedish Financial Supervisory Authority’s regulations on measures against money laundering and terrorist financing.
• Recommend measures: Propose improvements based on observations.
• Internal reporting: Prepare an AML annual report on the AML work.
• External reporting: Submit reports to the Financial Intelligence Unit when reporting suspicious transactions arising from a suspicious transaction or suspicious activity.

An AML specialist, by contrast, has a more operational mandate. The specialist performs concrete analyses, provides day-to-day support to the organisation and is the person who actually investigates complex cases. It is a particularly valuable complement to manage workload, secure specialist expertise and strengthen objectivity, especially where AML compliance consulting support is needed quickly and pragmatically.

At Morling Consulting we offer qualified AML specialists who can assist the CFA role with both ongoing support and targeted reviews. We always work from a strategic AML perspective shaped by your business needs and risk profile, spanning areas such as beneficial owner identification, reporting suspicious transactions and robust AML risk management.