How to prepare the AMLCO Annual Report in 2025
Regulated entities are required to fulfill several compliance obligations throughout the year, making them accountable to their respective supervisory authorities, such as the Cyprus Securities and Exchange Commission (CySEC) or the Central Bank of Cyprus (CBC). One of the most critical responsibilities is the preparation of the Annual Anti-Money Laundering Compliance Officer (AMLCO) Report. This report must be compiled by the company’s designated AMLCO and submitted to the regulator each year.
In today’s dynamic regulatory landscape, the Annual Anti-Money Laundering Compliance Officer (AMLCO) Report is more than a statutory obligation, it’s a cornerstone of a company’s commitment to financial integrity and regulatory compliance. For entities offering investment, crypto-asset, and payment services, this report serves as a comprehensive review of their AML/CFT (Anti-Money Laundering and Countering the Financing of Terrorism) framework.
Within this commentary the SALVUS Regulatory Compliance Team analyses the following aspects of the AMLCO Annual Report:
1. Executive Summary
2. Legislation
3. Organizational Structure, AML Manual and Suspicion Reporting
4. Findings and Recommendations
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1. Executive Summary
The executive summary serves as a concise overview of the entire report, summarizing its key findings, weaknesses, and recommendations for the convenience of senior management and regulatory bodies. In terms of documentation, according to CySEC’s C186 executive summary is an integral part of the report, and the report should be no more than 2-3 pages.
2. Legislation
A key section of the Annual AMLCO report outlines the applicable regulatory framework, which forms the foundation of the anti-money laundering and counter-terrorist financing (AML/CFT).
This includes national AML/CFT laws and European AML Directives. The report should not simply list these laws but provide a detailed account of any recent or upcoming legislative changes. For instance, the AMLCO must identify new provisions, amendments to existing articles, or the introduction of new directives that may have been announced or are anticipated. The report must then explain the potential impact of these changes, detailing how they adjustments are done in the company’s operational procedures, customer due diligence (CDD) processes, or risk assessment methodologies.
Beyond the core laws, the report must also give significant attention to secondary legislation and guidance. This includes directives, regulations, and circulars issued by national regulatory bodies, which elaborate on the broader legal requirements, offering specific instructions on areas such as enhanced due diligence (EDD) for high-risk clients, the reporting of suspicious activities, or the implementation of internal controls. The report should not only reference these documents but also provide an in-depth analysis of their contents, explaining how the company has integrated their guidance into its daily operations and overall compliance framework.
The report must also acknowledge and incorporate the role of international organizations, which are instrumental in shaping its AML/CFT standards. Key among these is the Financial Action Task Force (FATF). The AMLCO Report should reference key FATF documents and public statements which used as reference. In summary, this section of the Annual AMLCO Report provides a holistic view of the regulatory environment. It moves beyond a simple checklist to offer an insightful analysis of how legal and regulatory developments are monitored, interpreted, and applied.
3. Organizational Structure, AML Manual and Suspicion Reporting
Organizational Structure
The Annual AMLCO Report examines the company’s organizational structure to demonstrate a clear and accountable approach to AML/CFT compliance. This includes detailing the roles and responsibilities within the AML Department, which provides transparency to the regulator. The report should explicitly state that the duties and responsibilities for the AMLCO, AML Director, and Alternate AMLCO are formally documented. This structure ensures that governance and oversight are clearly defined, preventing gaps in responsibility.
The AML Manual
The company’s AML Manual is a central element of the report. Serving as the definitive guide for all AML/CFT policies, procedures, and controls. It functions as the entity’s blueprint for compliance, translating regulatory obligations into clear, actionable instructions for all employees. The report must confirm that the manual is comprehensive and up to date, reflecting all current regulatory requirements relevant to the company’s operations.
Suspicion Reporting
Suspicion reporting plays a key role, helping to identify and spot potentially suspicious and illicit activities, which is the result of an effective AML/CFT framework. The report must detail the company’s internal and external reporting procedures. It should outline the process for internal reporting, where employees report suspicious activities to the AMLCO, and the subsequent external reporting, where the AMLCO submits a report to MOKAS. The report should also provide details of the internal suspicious report received over the year and identify those reported to MOKAS.
4. Findings and Recommendations
One of the most important parts of the AMLCO Annual Report is where the findings and recommendations are explained.
Throughout the year, the AMLCO reviews key areas of the company’s AML/CFT framework. This includes everything from how customer due diligence is handled, to how transactions are monitored, to how internal policies are followed. But it’s not just about what was reviewed, it’s about what was discovered.
This section provides a clear roadmap for improving the company’s anti-money laundering and counter-terrorist financing (AML/CFT) framework, giving a transparent view of its compliance health to both internal management and external regulators. Also, provides recommendations to address findings and strengthen AML/CFT standards.
Final Thoughts
Crafting the Annual AMLCO Report requires a meticulous approach and strict adherence to regulatory guidelines. Every part of the report, from the Executive Summary to the deep dive into legal compliance is crucial for showing an entity’s dedication to preventing money laundering and terrorist financing. For professionals like AML Compliance Officers (AMLCOs) at Cyprus Investment Firms (CIFs), Crypto-Asset Services Providers (CASPs), and Payment Services firms, knowing how to create a thorough AMLCO Report is essential.
In response to this demand, SALVUS Funds, in collaboration with the Institute for Professional Excellence (IforPE), presents a self-study course titled “How to Prepare the AMLCO Annual Report in 2025”. Drawing from the extensive expertise of our Regulatory Compliance team, this course offers valuable insights into the intricacies of report preparation. By undertaking this course, professionals will acquire the knowledge and skills necessary to prepare a sound AMLCO Annual Report that meets regulatory standards.
The SALVUS Regulatory Compliance team can support CIF, CASP and other CySEC and CBC regulated entities, to fulfil their AML/CFT regulatory and reporting obligations and prepare your Annual AMLCO Report through our Anti-Money Laundering Consulting Service.
Contact us at info@salvusfunds.com if you require further guidance on the preparation of your Company’s AMLCO Report or if you have enquiries about our AMLCO Annual Report course with IforPE.
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The information provided in this article is for general information purposes only. You should always seek professional advice suitable to your needs.