Compliance officer, compliance manager, MLRO: roles and differences

Short answer: Compliance officer vs compliance manager: the officer applies the rules day to day through advice, controls, training and documentation; the manager runs the compliance programme, from risk assessment and policies to reporting. The MLRO is the statutory anti-money laundering role: the Geldwäschebeauftragter under section 7 GwG in Germany and the Geldwäschereifachstelle under Art. 24 GwV-FINMA in Switzerland.

This glossary guide is for executive boards, heads of compliance and HR teams in Switzerland and Germany. It explains what each title usually covers, where the roles overlap and how the anti-money laundering function differs between the two countries, so you can describe vacancies, cover and interim assignments accurately.

The roles at a glance

The titles overlap because organisations use them differently. The table shows the usual split; what counts in practice is the job description in your organisation.

Compliance officer: the day-to-day role

A compliance officer makes sure the rules hold up in daily business. The role is the first point of contact for the business and works close to it.

• Advise: answer questions on policies, conflicts of interest, gifts and hospitality.
• Control: run checks under the control plan, record exceptions and follow them up.
• Review: work through client, transaction and third-party reviews, such as KYC files in financial institutions or supplier due diligence in industry.
• Train: prepare and deliver training and keep attendance records.
• Document: record decisions, reviews and control results so that internal audit and the supervisor can follow them.

The role exists at every level. Junior professionals with 0–2 years of experience handle clearly defined reviews, experienced professionals with 3–6 years work independently, and seniors with 7+ years take on complex cases. In our experience, experienced is the most common level for interim assignments. What an interim compliance officer delivers and how to prepare the assignment is covered in Interim compliance officer: tasks, requirements and engagement models.

Compliance manager: steering the programme

A compliance manager is responsible for the compliance programme working as a whole. The role plans more than it reviews.

• Prepare the compliance risk assessment and keep it up to date.
• Adapt policies and processes to new rules.
• Set the control plan and evaluate the results.
• Prepare reports for the head of compliance, the executive board or committees.
• Lead a small team or guide compliance officers.

Smaller organisations often have one person covering both roles, titled compliance officer or compliance manager depending on the company. When you write a job profile or brief an interim professional, describe the tasks rather than relying on the title.

Head of compliance: leading the function

The head of compliance, or chief compliance officer, leads the compliance function and reports to the executive board and the supervisory body. The role sets the compliance strategy, owns budget and team, and represents the function towards internal audit, the external auditor and the supervisor. If the head of compliance leaves, the typical scenario for a leadership vacancy shows how an interim head of compliance bridges the gap.

MLRO: the anti-money laundering function

MLRO stands for money laundering reporting officer, the person responsible for anti-money laundering prevention. The term is common in English-speaking markets; German and Swiss law use their own titles.

Germany: Geldwäschebeauftragter (AML officer)

• Obliged entities such as credit, financial services and payment institutions must appoint an AML officer at management level and a deputy, reporting directly to the executive board (section 7(1) GwG, the German Anti-Money Laundering Act).
• Appointment and removal must be notified to the supervisor in advance. The AML officer is not bound by instructions on suspicious activity reports and enjoys special protection against dismissal until one year after removal (section 7(4), (5) and (7) GwG).
• The function can be outsourced after notification. BaFin requires notice at least two weeks before the start and always treats such outsourcing as material (BaFin interpretation and application guidance on the GwG, July 2025, sections 3.2.6 and 3.10).

Switzerland: Geldwäschereifachstelle (AML unit)

• Financial intermediaries supervised by FINMA designate one or more qualified persons as their AML unit. It advises line management and the executive board without relieving them of responsibility, prepares internal policies and plans training (Art. 24 GwV-FINMA, the FINMA Anti-Money Laundering Ordinance).
• External specialists are permitted where size or organisation makes an internal unit impossible or disproportionate; responsibility stays with the institution (Art. 25(4) GwV-FINMA).

When an interim MLRO fits and when an AML project team is the better choice is covered in Interim MLRO or AML project team?

Switzerland and Germany: different titles

Compliance officer, compliance manager and head of compliance mean the same in both countries. The differences lie in the anti-money laundering function and the engagement model.

In Austria, assignments run as freelancing or as staff leasing through the German or the Swiss company.

Which role for which need

The need determines the role, not the title. Use this mapping when you brief an interim assignment:

1. Backlog of reviews or controls: one or more compliance officers, often experienced, or a team with a team lead for large backlogs.
2. New rules, outdated policies, risk assessment due: a compliance manager who revises the programme and guides the team.
3. Head of compliance absent: an interim head of compliance with senior experience of supervisors and boards.
4. AML function vacant or no deputy: a professional for the MLRO role, provided the engagement model and supervisory law allow it.
5. Remediation project: a project structure with a project lead and compliance officers; the formal AML function stays in-house.

Alpinum Solutions provides compliance officers, compliance managers and heads of compliance through staff leasing or freelancing, part-time or full-time at 20–100 %, as individuals or teams. Selected profiles are usually available within 48 hours; the start date is agreed between the client and Alpinum.

Limits and risks

• Formal functions: interim professionals can take on formal functions such as MLRO or compliance officer with regulatory responsibility, through staff leasing or freelancing. For the MLRO, regulatory restrictions may rule out an external mandate or require staff leasing. Statutory independence and responsibilities remain intact.
• Responsibility stays with the organisation: the executive board and governing bodies remain accountable for compliance, including when the AML function is filled externally.
• Steering by model: in staff leasing, the client directs the work and the professional is integrated into the organisation. In freelancing, the professional works independently within the agreed mandate.
• No legal advice from Alpinum: Alpinum is not a law firm. Questions of interpretation towards the supervisor are resolved by the organisation itself or with an external law firm.

Frequently asked questions on compliance officer, compliance manager and MLRO

What is the difference between a compliance officer and a compliance manager?

A compliance officer works operationally: advising the business, running controls and reviewing individual cases. A compliance manager steers the programme: risk assessment, policies, control plan, reporting and often a team. In smaller organisations, one person covers both roles. For vacancies and interim assignments, the tasks you describe matter more than the title you choose.

What does a compliance officer do?

A compliance officer applies the organisation's rules in daily business. That means advising colleagues, running controls, working through reviews such as KYC files or third-party due diligence, training staff and documenting decisions so that audit and supervisors can follow them. The role usually reports to a compliance manager or the head of compliance.

Is an MLRO the same as a Geldwäschebeauftragter?

In substance, yes. MLRO is the English term for the person responsible for anti-money laundering prevention. In Germany the role is the Geldwäschebeauftragter under section 7 GwG, with a deputy and prior notification to the supervisor. In Switzerland the GwV-FINMA speaks of the Geldwäschereifachstelle (Art. 24), which advises line management and the executive board.

Can an interim professional act as MLRO?

Yes, through staff leasing or freelancing, depending on the client's requirements and the rules in Switzerland, Germany or Austria. Regulatory restrictions may rule out an external mandate or require staff leasing. In Germany, appointment and outsourcing must be notified to the supervisor in advance; in Switzerland, Art. 25(4) GwV-FINMA governs the use of an external AML unit.

What level does an interim compliance officer need?

It depends on the task. Junior professionals with 0–2 years of experience suit clearly defined reviews, experienced professionals with 3–6 years work independently, and seniors with 7+ years handle complex cases, supervisor contact and leadership. In our experience, experienced is the most common level for interim assignments.

What does a compliance manager do?

A compliance manager steers the compliance programme as a whole. They prepare and update the compliance risk assessment, adapt policies and processes to new rules, set the control plan and evaluate the results. They prepare reports for the head of compliance, the executive board or governing bodies and often lead a small team. In smaller companies, one person combines the compliance officer and compliance manager roles.

What does a head of compliance do?

A head of compliance, often called chief compliance officer, leads the compliance function. They set the compliance strategy, own the budget and team, and report to the executive board and to the board of directors or supervisory board. They represent the function towards internal audit, the external auditor and the supervisor. If the role becomes vacant, an interim head of compliance can lead the function until a successor starts; the company steers the assignment.

Who is responsible for compliance?

Responsibility stays with the executive board and governing bodies, meaning the board of directors or supervisory board, even when tasks are filled externally. They set up a compliance function which, depending on size, consists of compliance officers, a compliance manager and a head of compliance. This function advises, monitors and reports. The business units themselves remain responsible for acting in line with the rules day to day.

Next step

Alpinum Solutions is the leading provider of interim legal & compliance in the DACH region. Tell us about the tasks, level and workload, and we will send selected profiles for staff leasing or freelancing.

• Interim compliance: compliance officers and compliance managers on an interim basis
• Interim compliance officer: tasks, requirements and engagement models
• Roles & practice areas: all guides on roles and practice areas
• Discuss your needs

Last updated: 11 November 2026.