Head of Compliance & MLRO

My client a European bank is looking to hire a Head of Compliance & MLRO for it's London office.

Job Purpose:

To support the Executive in achieving their Strategic Plan and objectives in a compliant manner by providing appropriate challenge and diligence.

To ensure that a strong compliance culture is recognised and embedded across the Bank.

To lead the management of compliance across the operations and implement policy to meet regulatory requirements enabling the business to respond to regulatory and legislative changes.

To fulfil the statutory obligations of the ‘Nominated Officer’, Head of Compliance and MLRO.

To hold and execute the requirements of the SMF 16 (Compliance Oversight Function) and SMF 17

(Money Laundering Reporting Function).

This Job Description should be read in conjunction with the SMF 16 and SMF 17 Statement of Responsibilities (SoR).

Responsibilities & Accountabilities

Accountable for ensuring all managers, as set out in the Organisation Chart; fulfil their responsibilities thereby ensuring that full regulatory and statutory compliance is maintained at all times within the Bank. In fulfilling the role of Head of Compliance, the Job Holder should work independently of but in cooperation with Internal Audit to avoid duplication of effort.

Overseeing and assisting Senior Management as required in the establishment and ongoing maintenance of the AML/CTF framework.

To constantly develop and maintain policies and procedures of the AML/CTF framework in line with evolving statutory and regulatory obligations.

Conduct an annual risk assessment of the Bank and map mitigating controls.

Oversight of First Line of Defense (1LoD) procedures and monitoring programmes to ensure that the unusual transactions are identified and analysed.

Receive and assess all internal Suspicious Activity Reports (SARs) with onward reporting to the National Crime Agency (NCA) when required.

To be the Bank’s point of contact with NCA and other regulatory, law enforcement and investigatory agencies on AML matters.

Respond to Production and other Court Orders and prepare evidence as appropriate.

Ensuring compliance with AML staff training obligations, including ensuring that all relevant staff receive effective training appropriate to their needs.

The MLRO is responsible for overseeing the sanctions and transaction monitoring regime within the Bank including its screening tools.

The MLRO will assist with the transition of any 1LoD responsibilities from 2LoD to the First Line

To develop and implement the Compliance Framework/Strategy for the bank to meet the regulatory requirements.

Ensure that the Bank consistently and effectively operates within all relevant regulatory and statutory requirements at all times. (Note: that the jobholder is not responsible for ensuring compliance with various Finance Acts and Corporation Tax Acts relating to the Bank’s accounting procedures and the Bank’s Annual Report and Accounts or the accuracy of such reports.)

Ensure that the Bank abides by the Banking: Conduct of Business Sourcebook.

Ensure that the Bank abides by the UK Corporate Governance Code to the extent agreed by the Board.

Advise senior management and staff on changes in the rules and regulations and compliance standards including keeping them informed about potential developments in this area.

Keep senior management and/or related departments notified as to applicable regulatory returns to be completed and timeframes for submission to the FCA/PRA/other Regulators.

Maintain and oversee record keeping, e.g. Gifts, Complaints Register, FCA/PRA registrations, SMR certification and approvals.

Maintain market and customer/consumer confidence in the Bank and ensure that the Bank’s Complaints Procedures are correctly followed and reports made to the FCA as appropriate.

Monitor and record the Bank’s compliance with the legal and regulatory requirements, including compliance rules and standards, as well as the Bank’s compliance procedures, through the establishment and implementation of a risk-based compliance monitoring plan.

Liaise with the regulators as necessary and handle any regulatory queries in an open and co-operative way.

Ensure that the Bank is in compliance with legislation relevant to the Bank’s activities

Management of the Financial Crime and Compliance function

Prepare and present the MLRO annual report

Be an active member of the Executive Risk Committee

Other Duties

The MLRO must ensure that an assigned deputy is adequately equipped to cover MLRO duties during any short absences (sickness, courses) and during annual holidays.

Assist staff with interpretation of rules and regulations and ensure that staff awareness is always at satisfactory levels.

Provide training on Compliance and Financial Crime related matters to bank staff.

Undertake other duties appropriate to the grade and character of the work as may reasonably be required. The list of duties in the job description should not be regarded as exclusive or exhaustive.

Senior Managers & Certification Regime

Execute the responsibilities of the SMF 16 (Compliance Oversight Function) and SMF 17 (Money Laundering Reporting Function).

Equal Opportunities

To be able to demonstrate a commitment to the principles of the Bank’s Equal Opportunities and to be able to carry out duties in accordance with this policy.

Key Competencies

Consumer Duty:All staff must be aware of and understand the FCA’s requirements regarding Consumer Duty (CD) incorporated in the Bank’s Policy and help the Bank to act in good faith towards customers, avoid causing them foreseeable harm, and enable and support them to pursue their financial objectives.

Fraud Prevention: Policy statement No.18. All management and staff must be alert to the possibility of fraud, ensuring that no action is undertaken on behalf of the Bank or a customer without a clear understanding of the purpose and background to the transaction.

Attention to Detail: Ensures that information is correctly processed, and that work complies with relevant internal/external rules, procedures, and regulatory requirements.

Teamwork: Works co-operatively with others; openly exchanging information where appropriate and supporting colleagues to achieve business goals.

Planning & Control: Achieves departmental goals by establishing priorities and managing time efficiently.

Leading others: Builds successful and motivated teams who consistently excel in the achievement of business goals. Commits time and effort to coach others in new processes or techniques, providing honest and constructive feedback.

Making good decisions: Selects the best course of action based on the available information and accepts personal responsibility for the outcome.

Bringing innovation to problem solving: Continuously improves the business by generating new and practical ways of doing things in order to solve problems and gain competitive advantage.

Adapting to change and uncertainty: Improves personal effectiveness in response to changes at work by identifying new learning and self- development opportunities that arise from the change and working towards them.

Training and Competence: Keep up to date with relevant developments in corporate governance, the Banks’ policies, models and Anti Money Laundering and Counter Terrorism Financing matters by taking annual tests as required.

Complete all mandatory training and internal certification of the Bank.

Self-Motivation: Carry out every task set to the best of your ability, looking for ways to improve performance and standards, setting personal goals at or beyond business expectations.

Making change work: Help the business to introduce changes to structures, processes, products, and services effectively and efficiently by focusing effort and commitment on making the change work.

Experience /Skills /Knowledge

Bachelor’s Degree or equivalent preferred.

Professional qualifications (e.g. ICA Diploma in Governance, Risk & Compliance or equivalent. ICA Diploma in Anti Money Laundering, ICA Diploma in Financial Crime Prevention or equivalent).

Minimum 10 years of experience in areas of compliance and holding SMF16 or having a strong regulatory compliance background and experience and looking to step up to an approved person role and experience in areas of anti-money laundering and financial crime prevention.

Minimum 10 years of experience in Financial Services.

Fully conversant with the Bank’s products, services and procedures.

Strong understanding of relevant UK regulatory requirements.

Detailed understanding of financial services compliance.

Ability to keep up-to-date with current and future regulatory changes that affect the firm’s business and informing relevant teams of the same.

Acts with integrity, due skill, care and diligence in carrying out the role and responsibilities.

Adheres to the ethical standards of behaviour and code of conduct issued by the FCA under the Senior Managers Regime.

Strong communications skills.