Compliance, Financial Crime and Risk

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Salary: £80K - London

Our Client is a full scope investment firm that is regulated and authorised by the UK Financial Conduct Authority.  They provide Japanese and EMEA focused invesmtent banking products to their European clients, and expert insights and innovative solutions in global securities and derivative products.  Their headquarters are in London, but also have offices in Sydney and Hong Kong.

The company is organised into two divisions: The Securities Product Group and Derviative Product Group.  Their activites include market analysis and research, broking and trading in primary and secondary debt and equity securities, advisory services on mergers and acquisitions, and marketing and trading over-the-counter derivative contracts.

AML Compliance co‐ordinates day‐to‐day implementation of the firm's financial crime preventionefforts. It includes several compliance disciplines and has responsibility for governance, oversightand execution of the firm's AML, economic sanctions, anti‐fraud, anti‐bribery and anti‐corruption. Itdevelops appropriate policies, procedures, including those designed to assist the business to knowtheir customers and conduct appropriate due diligence to prevent, detect, and report potentialsuspicious activity. The team advises each business unit regarding its AML, economic sanctions,anti‐fraud, anti‐bribery, and anti‐corruption obligations and its particular clients and transactions.The AML Team operates within the Compliance Function. Financial Crime Compliance also liaiseswith compliance teams thoughout the company to ensure that they are compliant with globalregualtory requirements.


Key Job Functions

Reporting to the Deputy Money Laundering Reporting Officer (DMLRO) of CM Ltd, responsible forproviding sound regulatory and practical advice on all matters relating to financial crime prevention,including, but not limited to, assessing the requirements and controls for countering financial crime;planning, implementing and revieweing policies and procedures to counter financial crime. Perfomvarious tasks to ensure that a strong compliance culture exists within CM Ltd, and to enable the firmto meet its commercial objectives in full compliance with regulatory requirements re AML,economic sanctions, anti‐fraud, anti‐bribery and anti‐corruption.

The major activities which comprise the job are:‐

  • act as an advisor to the business for enhanced due diligence processes, findings and escalations;‐ 
  • assess and mitigate financial crime risk associated with potential and existing clients of the firm via the enhanced due diligence reviews;‐ 
  • review and evaluate the implementation of organisation's financial crime prevention policy andprocedures;‐ 
  • continued enhancement of policies, procedures and technology to support financial crimecontrols;‐ 
  • present EDD findings in the risk acceptance forms for review and decision making by the BusinessHeads, the MLRO and the DMLRO;‐ 
  • act as an escalation point for the KYC team Operations onboarding and periodic review teams toensure that customers are reviewed and risk decisions made on the basis of robust analysys, in linewith internal policies and procedures;‐ 
  • stay abreast of Financial Crime related regulatory updates, enforcement actions and typologies,challenging existing systems and processes , looking for enhancements and efficiencies wherepossible;‐ 
  • rigorous oversight, within specified remit, over the work of the first line of defence via timelycompletion of quality assurance tests under compliance monitoring programme;‐ 
  • contribute to setting out and embedding a more advanced sanctions compliance framework andstandards;‐ 
  • support line managers in their efforts to meet leagl and regulatory responsibilities;‐ 
  • identify, co‐ordinate and implement enhancements of the AML & Financial Crime ManagementInformation ("MI");‐ 
  • assist with planning and delivery of the AML and Financial Crime training‐ 
  • ad hoc project work and reviews.

Specific tasks

Financial Crime Advisory:‐

  • checking that staff are aware of policy and procedure requirements;‐ 
  • encouraging staff to seek advice and guidance on AML and financial crime matters;‐ 
  • responding positively and helpfully to requests for advice and guidance within appropraitetimescale;‐ encouraging staff to provide feedback on the usefulness of the advice and guidance they havereceivedproviding appropraite feedback to staff on changes made due to requests for advice,guidance and infomration in line with organisation.

Sanctions Compliance:

Providing oversight of transaction monitoring and filtering programmes ‐ running compliance tests for:

  • validation of the integrity, accuracy and quality of data to ensure that accurate andcomplete data flows through the monitoring and filtering programmes;
  • data extraction and loading processes make sure that data is complete and accurate from itssource to automated and monitoring and filtering systems;
  • assisting with investigating of potential breaches, escalations, exceptions.

EDD File Analysis:‐

  • assessing materiality of PEPs and adverse media‐ 
  • feeding assessment results into customer risk assessment‐ 
  • escalating cases depending on materiality analysis‐ 
  • completing EDD, including source of wealth and source of funds review‐ 
  • facilitating risk understanding and acceptance by the Front Office‐ 
  • documenting the outcomes

Evaluate the effectiveness of systems and controls for countering financial crime:‐

  • determine the purpose and methodology of each test;‐ 
  • review data from internal and external sources;‐ 
  • conduct the tests;‐ 
  • ensure that accurate, up‐to‐date and complete records of the evaluation are maintained;‐ 
  • review decision trees and actions to be taken in response to findings to ensure compliance withpolicies, standards, procedures, and regulatory requirements;‐ 
  • identify non‐compliance and escalate;‐ 
  • record the outcomes of monitoring activities and present the informaiton to MLRO/DMLRO andthe AML Group;‐ 
  • qualitative fin crime MI.


General Financial Crime and Complaince:‐

  • conducting and documenting financial crime‐related CMP tests‐ 
  • helping with CIF design and UAT



  • other wider compliance tasking as required;‐ 
  • attending relevant compliance and AML meetings


Responsibility and Authority

 The major activities which comprise the job are:∙

  • Maintaining high standards in delivering key job function∙
  • Owning tasks and leading through to completion∙ 
  • Maintaining lists and logs∙ 
  • Answerable for correct and thorough completion of his/her individual task and deliverable


Organisational Structure

 AML/Fin Crime Compliance coordinates day‐to‐day implementation of the Firm's enterprise‐widefinancial crime prevention effort. The team presently consists of three full‐time employees,including the Deputy MLRO, and two contractors.



Key Stakeholders

The Compliance Department needs to understand and interact with all other parts of the business, front,middle and back, within the company worldwide, with clients, and with regulators, generally but not exclusively those that supervise our firm in the UK. The department is under close scrutiny from regulators, external auditors, internal auditors, other compliance functions within the group, and most immediately from the Executive Committee, the board and the various other bodies that govern the group. The department has wider outreach to,and greater attention from, other stakeholders than any other part of the business except the governing body.Key stakeholders for this particular compliance role are all of the above, and in particular business lines (both Securities and Derivatives Product Groups), IT/Systems, RiskManagement, and members of the Operations Department administering UK commercialrelationships’ on‐boarding, review, monitoring, record keeping, account opening and data management.


Specific Experience and Qualifications

An ideal candidate will have:‐

  • Strong experience in fin crime compliance advisory and assurance methodologies;‐ 
  • Strong technical knowledge of financial crime risks;‐ 
  • Previous experience of international financial crime risk identification and management;‐ 
  • Previous capital markets and banking experience.


Key Skills & Abilities

  • Degree educated or equivalent‐ 
  • At least 7 years experience of AML/Financial Crime Compliance in a securities house, broker dealerand/or wholesale banking;‐ 
  • Understanding of capital markets products and services;‐ 
  • Strong knowledge of financial crime compliance regulations in the UK;‐ 
  • Meticulous attention to detail;‐ 
  • Have the ability to effectively handle a fast paced environment and work to tight deadlines;‐ 
  • Be able to re‐prioritise work in response to changes in business needs, without compromisingstandards;‐ 
  • Be able to recognise and escalate risks and issues appropriately;‐ 
  • Strong understanding of risk factors associated with business relationships and capital marketsproducts;‐ 
  • Strong understanding outcomes and success criteria of customer due diilgence;‐ 
  • Ability to identify the action needed to improve the effectiveness of AML/Fin Crime policy,systems, arrangements, and controls;‐ 
  • Experience in unfolding diverse complicated corporate structures;‐ 
  • Strong communication skills adopting the style and approach to the audience and message to bedelivered;‐ 
  • Quick learning and strong understanding of policies, procedures, systems, processes of CMLimited;‐ 
  • Achievement orientation ‐ focusing efforts on achieving high quality results consistent with theorganisational standards;‐ 
  • Ability to make a critical evaluation of arguments, assumptions, concepts and data;‐ 
  • Clear understanding of the regulatory and commercial environments whichin which decisions to betaken.



Additional Information

 The nature of the company, its business lines, the markets it operates in and its stakeholders’geographical spread often requires the role to be available for non‐standard hours. Our Client has grown significantly since they opened  in 2010 and will continue to do so in line with the markets. With that, the pace of growth within the Company and its widening product range requires flexibility, willingness to adapt and the ability to embrace change.

For more information contact Duncan Tout

Recruitment Resourcer
Phone: 01732 746 668
Email Duncan

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