Head of Compliance

• MLRO to be responsible for the day-to-day management and control of Suspicious Activity Reporting and Disclosures made to the FIU and for the maintenance of the SAR register and MLRO records relating to such reports;
• MLRO to receive SARs from staff, acknowledge and evaluate to ensure that the information is considered and determined in a timely manner and in accordance with the Handbook;
• To externalise (where appropriate) SARs to the FIU within required timescales or report to the Board Compliance and Risk Director with reason for non-delivery;
• To ensure that the relationships are reviewed post-reporting and ensure all are reminded to avoid tipping off any third parties.
• Follow up reviews of cases to close and archive;
• To develop and maintain effective controls, including PPCs and any relevant schedules or registers, in respect of reporting including guidance on the laws and typologies / trends;
• Board reporting

• To undertake regular reviews (including testing) of the effectiveness of PPCs to counter money laundering and the financing of terrorism and of compliance therewith.
• To assist the Board to ensure that all business which the business operates is conducted in strict compliance with all money laundering laws orders, and regulations in force and the business's own policies and procedures in this area, reporting any deficiencies and recommending changes.
• To act as liaison point and respond promptly to requests for information made by the GFSC, FIU and Chief Minister's Department.
• To report periodically, as appropriate to the Board on compliance with the business systems and controls.
• To keep abreast of all new legal & regulatory developments in respect of anti-money laundering and terrorist financing, and sanctions matters, and report matters of significance to the Board.
• To ensure that recommendations are provided, where required, to the Board in relation to the enhancement of the business's AML/CTF/CPF policies, procedures, systems and controls.  Compliance Officer.
• To implement and supervise a Board approved risk-based CMP to ensure compliance with all laws, Codes, orders and regulations in force and the business's own policies and procedures and produce appropriate reports to the Board.
• To review and/or have oversight of new business to ensure CDD is in compliance with AML legislation and policies.

• To develop and maintain effective systems and controls, including PPCs and any relevant schedules or registers, for countering money laundering and the financing of terrorism, and mitigate any sanctions risks which may arise.
• To keep abreast of all new legal & regulatory developments (particularly in respect of anti-money laundering and terrorist financing) and report matters of relevance to the Board and suggest, where necessary, changes to PPCs.
• To provide reports to the Board and any committee meetings as required.
• To assist in the preparation for any regulatory visit and to attend, as appropriate, any such visit.
• To attend in-house meetings from time to time, including for training, as may be required.
• To provide training to other staff members on regulatory and compliance issues as and when required.  To ensure that staff are aware of their personal obligations and the internal PPCs. To maintain training records for AML.
• To be responsible for reviewing the completed Annual Declarations from all staff and reporting any issues annually on the Board Report.
• To be responsible and oversee the training plan and provide a general training update annually on the Board Report. To maintain AML/CTF/CPF training records.
• To be proactive in assisting with streamlining and improving the running of the office by suggesting improvements for the Board's consideration for efficiency and enhancement.
• To be responsible for the timely notification to the GFSC of changes in senior personnel and other required notifications in accordance with the regulations and timescales set out.
• To provide and arrange compliance sign off on publications, advertising and other material which is made available to the public or Clients.  

• To ensure that filing and compliance records / files including archive records etc are properly maintained and satisfy legal and regulatory requirements.
• To assist the business in conducting its affairs in full compliance with the laws, orders and regulations,
• To discharge functions in a professional and courteous manner and carry out any other duties as may be required from time to time by the Board.
• To complete the annual appraisals in accordance with PPCs.
• To undertake any other task as may be reasonably requested.
• To be available to undertake additional hours as may be reasonably requested.
• To maintain accurate records of time spent on each entity and ensure that entity records are updated daily.  To monitor same for any direct reports (temporary or otherwise) and address effectively any deficiencies.
• To supervise, mentor and support other members of the Compliance & Risk team as required and provide on the job training and advice to direct reports or to other junior members of staff.
• To manage any fixed term / project workers as necessary and ensure appropriate allocation of fair workloads.  To assist and re-distribute as necessary in order to meet deadlines.
• To lead by example managing direct reports and provide guidance and support to ensure the smooth running of the team with a good steady morale.
• For direct reports and with guidance from HR, deal with any issues relating to poor performance and/or behaviour and conduct promptly and sensitively in accordance with the Staff Handbook ensuring adequate file notes are maintained.
• To ensure that all scheduled staff absences such as holidays and training are adequately monitored and covered.
• With assistance from HR, conduct probation review meetings and Return to Work interviews as necessary.  Handle any issues relating to poor attendance due to sickness or timekeeping ensuring adequate records and file notes are maintained.
• To conduct appraisals for direct reports (and self) in accordance with the policies and procedures and provide advice in relation to training and development issues.
• To assist with the recruitment of staff within your area of responsibility and ensure new staff are welcomed to the business assisting with the induction process for new joiners as appropriate.

• Be a 'fit and proper person' who can demonstrate the highest level of ethics and integrity in dealings with staff at all levels plus external contacts and stakeholders;
• Hold relevant compliance qualification (e.g.: international compliance association) or experience;
• Possess a high level of maturity and experience to demonstrate autonomous thinking and independence from colleagues, clients and the Board
• Excellent organisation, communication (both orally and written) and time management skills with all round good inter-personal communication and relationship skills.
• Ability to work on own initiative under pressure and meet deadlines.  Accuracy and attention to detail are vital.
• Good understanding of the business and analytical skills and technical abilities necessary to undertake independent reviews / monitoring at a high professional standard.
• Problem-solving skillset, including identification of deficiencies and inefficiencies, and proposing appropriate solutions to remediate.
• Senior Compliance and Management Experience in a TCSP role, ideally 5+ years in a Supervised role of CO/MLCO/MLRO.
• Possessing relevant qualification, e.g., ICA Diploma level accreditation, which demonstrates a thorough understanding of all relevant requirements.   
• Annual CPD Requirements. To complete 25 hours of CPD or, if greater, such amount required to maintain professional qualifications.

Your specialist: Sally Fenton

Quote job ref: 14702

Hi, I'm Sally and this is one of the job roles I am looking after for this super business. If this job is of interest for you, please submit your CV and we will come back to you to arrange the next staging.

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