The Act specifies four functions and a condition that there be no conflict of interest. A Nominated Compliance Officer as we understand it undertakes the role of monitoring compliance with AML/CFT obligations and reports directly to the Supervisor of Banks in relation to the same. A perusal of the statute under which the Nominated Officer operates charges them with the substantive tasks of monitoring and reporting on threshold limits and public education in relation to the various policy papers as may be issued by the Bank of Jamaica or other institutions in addition to reporting to the Board at least once yearly.
Whilst the levels of responsibility are similar in relation to the Nominated Officer and the Data Protection Officer, they are two separate and distinct roles that will operate in two separate reporting regimes aspects of which carry time-bound reporting criteria. It may not be ideal that the duties under both reporting regimes be entrusted or the task of one individual as it may create reporting conflicts as well as other management issues.