Client Compliance Officer, MLCO, MLRO – Compliance

Summary of role

Responsibility for ensuring that the portfolio of client entities assigned to you have comprehensive and effective system and controls in place to maintain compliance with relevant legal and regulatory requirements, to advise on such systems and controls and to monitor for compliance with them.

You  will  be  appointed  as  the Compliance  Officer  (“CO”),  Money  Laundering  Compliance  Officer  (“MLCO”)  and  Money Laundering Reporting Officer (“MLRO”) for certain client entities, which may include managed entities, unclassified (or materially equivalent non-domiciled) funds (which may include listed and expert funds), JPFs and PPFs.

Job Specification

Technical / Regulated

• Serving as CO, MLCO and MLRO to the allocated client entities.
• Operating within the defined MLRO policy and procedures including, but not limited to:
  • Management of all suspicious activity report (“SAR”) activities within established timeframes and liaison with the JFCU.
  • Ensuring internal and external relationships are managed effectively mindful of tipping off requirements
  • Maintaining the various registers and the MLRO actions tracker / reporting of any actions required.
  • Guiding the business / client entities to comply with the terms of consent or non-consent letters and subsequent production and/or restraint orders and coordinating required action upon such directions.
• Responsibility for providing Compliance support and direction to the client entities on AML/CFT matters and the SAR process.
• Embedding a compliance culture within Apex and through personal engagement with client entity boards / committees.
• Ensuring client entity boards are kept apprised of industry best practise.
• Ownership and delivery of all relevant reports at the client entity board / committees and reporting to Apex Group Compliance, as applicable.
• Review and sign off of ‘new customer’ and ‘trigger event’ customer due diligence, as required, in conjunction with the MLCO support.
• Maintenance of client entity policies, procedures and controls, ensuring consistency with group standards and relevant legal and regulatory obligations, including mapping to relevant changes to the framework / JFSC industry feedback.
• Undertaking the client entity Compliance monitoring and guiding the client entity boards in relation to its planning, alongside the AML/CFT BRA.
• Coordinating the JFSC’s risk-based supervision data collection and responsibility for other periodic regulatory returns.
• Supporting the Head of Compliance in managing regulatory visits and liaising with the JFSC.
• Working with the client entities / business to raise awareness of relevant emerging and existing legal and regulatory requirements and developments.
• Ensuring that all material matters identified are appropriately reported and escalated.
• Providing mandatory AML/CFT and SAR training to client entity boards, as required.
• Driving forward the development, implementation and embedding of SAR, AML/CFT and associated regulatory policies and procedures, including robust control procedures.
• Responsibility for the client entity screening process and various Compliance registers and reviews (including assisting with new business).
• Assisting with the regulatory aspects of client entity audits.
• Conducting ad hoc reviews and/or special investigations as required.

People

• Team management, including regular 1:1s, appraisals and development meetings.
• Providing support and direction and sharing examples of best practice with relevant business areas and colleagues.