Head of Compliance & MLRO/Chief Compliance Officer

Principal Purpose of the role:

Duty: The Head of Compliance/CCO (SMF16) & MLRO (SMF17) has a duty to the Bank to work with management and staff to identify and manage regulatory risk and the risk that the Branch may be used for the purposes of financial crime.

Objective: The overriding objectives of the Head of Compliance/CCO (SMF16) & MLRO (SMF17) should be to ensure that the Branch has systems and internal controls that adequately measure and manage the regulatory and financial crime risks it faces.

Responsibility: The general responsibility of the Head of Compliance/CCO (SMF16) & MLRO (SMF17) is to provide an in-house compliance service that effectively supports business areas in their duty to comply with relevant laws and regulations and internal procedures.

Main Responsibilities and Accountabilities:

1. To act as the first point of contact with both the PRA and FCA.
2. To identify the regulatory, including financial crime, risks that the Branch faces and advise on them (identification) by,

• Maintaining a high level of personal awareness with regard to regulatory and financial crime matters including new national and international developments and changes to regulation;
• Identifying potential areas of compliance vulnerability and risk;
• Maintaining the Branch’s financial crime risk assessment by conducting regular risk assessments on the branch’s customer base together with the products and services offered by the Bank and ensuring appropriate mitigating controls are in place.

1. To design and implement controls to protect the Branch from those regulatory and financial crime risks (prevention) by,

• Developing, initiating, maintaining and revising policies and procedures, systems and controls for the general operation of the Compliance and Crime Prevention Programs and their related activities to prevent illegal, unethical, or improper conduct;
• Together with overseeing the management of the day-to-day operation of the Programs.

1. To monitor and report on the effectiveness of those systems and controls in the management of the Branch’s exposure to regulatory and financial crime risks (monitoring and detection) by,

• Developing and periodically reviewing and updating Standards of Conduct to ensure continuing currency and relevance in providing guidance to management and employees;
• Monitoring the performance of the compliance and financial crime prevention program and related activities on a continuing basis, taking appropriate steps to improve its effectiveness;
• Monitoring, and as necessary, coordinating compliance activities of other departments to remain abreast of the status of all compliance activities and to identify trends;
• Responding to alleged violations of rules, regulations, policies, procedures, and Standards of Conduct by evaluating or recommending the initiation of investigative procedures, including the development and oversight of a system for uniform handling of such violations;
• Acting as an independent reviewer to ensure that any compliance issues/concerns within the Branch are being appropriately evaluated, investigated and resolved;
• Providing reports on a regular basis including the regulatory Annual MLRO Report, and as directed or requested, to keep the Head Office Compliance Committee of the Board and senior management informed of the operation and progress of compliance and crime prevention efforts;
• Ensuring proper external reporting of violations or potential violations to duly authorised enforcement agencies as appropriate and/or required;
• Acting as the central point of contact for all activity within the Bank relating to financial crime including;

1. Policy maintenance and development in line with statutory and regulatory obligations;
2. Developing internal procedures;
3. Receiving and reviewing ISRs and taking reasonable steps to assess all relevant information to decide whether suspicions should be reported to the NCA and, if appropriate, make the necessary SAR;
4. Ensuring that all employees complete the Half-yearly Suspicious Transaction Acknowledgement Form;

• Acting as the central point of contact with all regulatory and official investigating agencies in the UK in relation to regulatory compliance and financial crime prevention, issues. E.g. FCA, NCA, DWP, Police and HMRC.

1. To resolve compliance difficulties as they occur (resolution) Developing and implementing corrective action plans for resolution of problematic issues, and providing general guidance on how to avoid or deal with similar situations in the future.
2. To advise the business on rules and controls (advisory) by,

• Collaborating with other departments (e.g., Risk Management, Internal Audit, Employee Services, etc.) to direct compliance issues to appropriate existing channels for investigation and resolution;
• Consulting with the Branch’s Lawyer as needed to resolve difficult legal compliance issues;
• Instituting and maintaining an effective compliance and financial crime prevention communication program for the Branch, including promoting;

1. The use of the Compliance ‘open door’ policy;
2. A heightened awareness of Standards of Conduct, and;
3. An understanding of new and existing compliance and financial crime issues and related policies and procedures.

• Working with the Admin & HR Department and others as appropriate, to develop an effective compliance training program, including appropriate introductory training for new employees as well as ongoing training for all employees and managers.

To be successful in the role, the following key skills are essential:

• A Bachelor degree or above, ideally of a legal or business related educational background;
• Current approved SMF16/SMF17
• 10+ years’ experience in corporate/institutional banking compliance role within the financial industry is preferred;
• Team managing experience;
• Deadline driven and ability to work under pressure;
• Excellent communication.

This will be a full-time position and the successful candidate will receive a highly competitive salary and package based on their experience.