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Head of Compliance and AML (PCF 15)

Information About This Job

Job Title: Head of Compliance and AML (PCF 15)
Contract Type: Permanent
Location: London
Contact Name: Mark Foy
Contact Email:
Job Published: 9 months ago

Job Description

Key Responsibilities

  • Primarily responsible for the operation of the Company's permanent and independent compliance function.

  • The compliance function has the following responsibilities:  

    • a) monitoring and, on a regular basis, evaluating  the adequacy and effectiveness of the measures, policies and procedures put in place and the actions taken to address any deficiencies in the Company’s compliance with its obligations;

    • b) advising the relevant persons responsible for carrying out investment services and activities to comply with the Company's obligations under the Regulatory Framework, while ensuring the Company’s compliance with their obligations under the Regulatory Framework;

    • c) to report to the Board, on at least an annual basis, on the implementation and effectiveness of the overall control environment for investment services and activities, on the risks that have been identified and on the complaints-handling reporting as well as remedies undertaken or to be undertaken;

    • d) to monitor the operations of the complaints-handling process and consider complaints as a source of relevant information in the context of its general monitoring responsibilities; and

    • e) the compliance function reports on an ad-hoc basis directly to the Chief Executive Officer and the Board where it detects a significant risk of failure by the Company to comply with its obligations under MiFID;

  • Assess any compliance issues reported to the Head of Compliance.

  • Review and approve all tied agent candidates based on their qualifications and background check.

  • Maintain control procedures in the Procedures Manual.

  • Confirm that outsourced functions are in compliance with the Company’s obligations under the Regulatory Framework and its outsourcing policy

  • The compliance function conducts an assessment on the basis of which it shall establish a risk-based monitoring programme that takes into consideration all areas of the Company's investment services, activities and any relevant ancillary services, including relevant information gathered in relation to the monitoring of complaints handling. The monitoring programme shall establish priorities determined by the compliance risk assessment ensuring that compliance risk is comprehensively monitored.

  • The Head of Compliance is responsible for ensuring appropriate policies and procedures are in place with respect to the investment activities undertaken by the Company.  The Head of Compliance will engage with the relevant personnel from the investment, risk, compliance, operational and legal teams of the Company and the Group to put in place the Procedures Manual.

  • With regard to monitoring the Procedures Manual, the Head of Compliance will assign a first-line owner to each policy, being a representative of the relevant business unit charged with responsibility for implementing the policy on a day to day basis (“BU Owner”).  The Head of Compliance will agree a reporting and escalation procedure with each BU Owner, under which the BU Owner will provide ongoing reporting to the Head of Compliance in respect of activities undertaken for the period and will confirm adherence to the relevant policy/ies and or notify the Head of Compliance of any deviations, breaches or exceptions to the policy, or any proposal to update or amend the Procedures Manual. Reporting will typically be received on a monthly basis, with exceptional items notified on an ad-hoc basis as they occur. The reporting received from the relevant BU Owners will form the basis of the quarterly reporting which the Head of Compliance will provide to the Board.

  • The Company's permanent compliance function has the necessary authority, resources, expertise and access to all relevant information including, where appropriate, when located at the Branches. The Head of Compliance will be informed of all compliance issues.

  • The Head of Compliance will be responsible for compiling and implementing a compliance plan on an annual basis and will also undertake compliance testing at least annually. On an annual basis, the Head of Compliance will prepare a Schedule of Testing, setting out areas of proposed testing for the year ahead, which will be based on a number of factors including the significance of the activity in the context of the Company's operations, the level of risk attaching to the activity, and will take account of current Central Bank agenda for thematic reviews and areas of focus. As part of this testing, the Head of Compliance will undertake spot checks and sample-based analysis to ensure that the Procedures Manual is correctly and effectively implemented in practice and mechanisms for escalation and reporting are adhered to.

  • The Company's annual training procedures, as outlined at section 4 above, will include an overview of the compliance procedures and each member of staff will be provided with a copy of the Procedures Manual.

  • The Head of Compliance is not involved in the performance of services or activities it monitors and the method of determining the remuneration of the Head of Compliance does not compromise its objectivity and is not likely to do so.

  • The Head of Compliance will provide a formal report on a quarterly basis to the Board on any legal or regulatory developments which have been identified to the Head of Compliance which may have a material impact on the Company and will otherwise confirm that the Company has carried out its services and activities in compliance with the Company’s obligations under the Regulatory Framework and will also keep senior counsel of the parent fully informed.

  • In addition to the Head of Compliance's quarterly report, the Head of Compliance will report ad hoc issues promptly to the Chief Executive Officer and senior counsel of the parent company, including the Board of Directors to the extent warranted by a particular incident or incidents.

  • Compliance issues may be dealt with by the Head of Compliance as they occur. Where required, a Board Meeting will be specially convened to address such matters.

  • Monitoring of compliance also includes the maintenance of logs on the Company's behalf in respect of complaints and compensation payments, all of which are available for inspection by the Central Bank.

  • The Head of Compliance maintains and keeps up to date a record of the activities undertaken by or on behalf of the Company in which a conflict of interest entailing a material risk of damage to the interests of its clients may arise.

  • Oversight of AML process and procedures.

  • The Head of Compliance will confirm that, where relevant, the service providers implemented measures on behalf of both the Company to comply with its obligations respectively to (i) establish the identification of clients; (ii) keep adequate records; (iii) prevent and detect the commission of a money laundering offence; (iv) report suspicious activity to the Head of Compliance; and (v) train its officers and employees as required by the CJA. The Head of Compliance will also receive and assess reports of suspicious transactions and communicate such reports on to the Garda Síochána and the Revenue Commissioners, obtain, on behalf of the Company, a quarterly confirmation from the any relevant service provider as the Head of Compliance deems appropriate as to its anti-money laundering policies and procedures, and that such other service provider has complied with its obligations in the provision of services to the Company and report on a quarterly basis to Board meetings as to (i) any suspicious transaction reports made by the Company during the relevant period (ii) any issues arising out of the confirmation(s) received. In between quarterly reporting periods, the service providers will notify the Head of Compliance of any suspicious transactions occurring in the interim and provide the Head of Compliance with an ad hoc report of such transactions if required. In turn, the Head of Compliance will notify the Board of any suspicious transactions relating to the Company which the Head of Compliance is made aware of in the interim.

  • Provide an annual compliance report to the Board covering policies and procedures designed to detect any risk of failure by the Company to comply with its obligations under MiFID

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