Statutory appointments

The posts

Some responsibilities belong to a named person because the law says so. The firm starts with three posts: the anti-money laundering reporting officer (Anti-Money Laundering Act, 2020, Act 1044), the data protection supervisor (Data Protection Act, 2012, Act 843) and the client account partner. Add post adds any other the firm keeps, with the law or rule that requires it.

Settings, Compliance, Appointments lists the posts with who holds each, their deputy, since when, and how the post stands: Held, No deputy, Expiring (within thirty days), Expired or Vacant.

Appointing someone

Open a post and choose Appoint someone. Name the holder and their deputy, the day the appointment starts, when it lapses if it does, the day the regulator was told and the reason, such as the partners' resolution. Appointing a successor ends the current appointment the day before the new one starts. Every appointment is kept in the post's history.

Edit the appointment changes the deputy, the expiry and the day the regulator was told. End the appointment records the day and why; the post stands vacant until someone is appointed.

Who hears what

The holder and the deputy of each post hear the notices the law makes theirs, whatever their role. The AML reporting officer hears of reports to the Financial Intelligence Centre coming due, overdue or waiting for approval, of concerns raised, of possible screening matches and of cash transactions to report. The data protection supervisor hears of each data subject request. The client account partner hears when a cheque comes back after money was paid against it.

Each morning, whoever appoints (the managing partner, by default) is told once when a post stands vacant, runs out within thirty days or has run out.