Compliance Manager - Wealth Management
Main Job Purpose
The Compliance Manager for Wealth Management (“WM”) activities in Jersey works in coordination and in support of the Channel Islands (“CI”) WM Head of Compliance. He/she undertakes the corresponding duties in accordance with the local applicable regulation and BNP Paribas guidelines, policies and procedures helping to identify and manage the compliance risk across the WM Jersey entities.
The incumbent will work in conjunction with Operational Permanent Controls and other functions as appropriate to achieve the objectives of the Compliance function, notwithstanding existing responsibilities allocated to each function.
In addition he/she will:
· Deputise for the CI WM Head of Compliance when required.
· Hold the Key Person positions of MLRO and MLCO for certain entities.
The key responsibilities will be working with the CI WM Head of Compliance in the day-to-day management of the compliance framework of WM Jersey (Branch / Trust activities) as per below:
- Ensure activities are organised and executed in accordance with the requirements of the applicable regulatory framework, professional and ethical standards.
- Making sure activities (including those outsourced) are exercised correctly with regards to the primacy of customer interests, market integrity, procedures, Group and/or the Territory Compliance function policies.
- Ensure that the ethical policies (staff dealing, anti-fraud, conflicts of interest, personal account dealing and whistleblowing) and framework are maintained.
- Assist in the analysis and reporting of matters relating to the protection of the interests of clients.
- Ensure that a risk based approach is enshrined within the compliance processes and in particular those relating to AML/CFT and financial sanctions.
- Act as MLRO and MLCO for the WM entities (as per the separate job descriptions).
- Appraise WM business line management of regulatory changes applicable to WM activities and provide guidance on interpretation / application of the requirements.
- Ensure timely and accurate notification to the Jersey Financial Services Commission of any reportable matters specified in local regulations.
- Coordinate actions in relation to visits and inspections (internal / external).
- Respond promptly to requests for information on compliance related matters made by the Jersey Financial Services Commission.
- Identify / receive / record / follow-up regulatory breaches, compliance related incidents and compliance related complaints. Advise on relevant actions to avoid re-occurrence and ensure corrective measures to compliance related problems have been implemented and are proven effective.
- Provide opinion as required on advertising and marketing materials and outsourcing arrangements in accordance with published procedure.
- Oversee that the Compliance Monitoring Plan is comprehensive and instigate corrective actions where applicable. Remain aware of the output ensuring issues of materiality are communicated to the business line an action plan is progressed to achieve remediation.
- Ensure that complaints are being monitored and recorded in an accurate and effective manner and the Jersey Financial Services Commission is notified where applicable
- Compliance reporting (Group Compliance Risk Management System (“CRMS”) and ad hoc reporting).
- Management of NORKOM (post-transaction alerts system).
- Management of ACTIMIZE MAD (Market Abuse Detection system).
- Application of suitability controls (semi-annual). Participation at suitability committees.
- Assist in preparation of the different reporting (Group, Board, ICC, Territory Compliance Committee) and attend in the absence of the CI WM Head of Compliance.
- Attend relevant business line meetings (weekly staff meeting, Risk Management Committee, business line management meetings etc.).
- Develop and organise delivery of training sessions (as appropriate).
- Liaise with auditors, (internal and external) and follow-up up recommendations made regarding compliance risks.
- Promote compliance awareness on subjects within the compliance area and assist in development of a compliance working culture.
- Attend New Product / New Activity / Transactions Approval Committees as required.
- Provide support and advice on AML/CFT and sanctions issues and the potential legal, regulatory, criminal and reputational risk associated with new and existing customers
- Review and sign-off of new and existing client files; communication with the business on findings; participation in Client Acceptance Committees.
- Participate in compliance related industry workshops where appropriate.
- Deputise for the CI WM Head of Compliance on all other matters when and if required.
- Input and validation of CRMS.
- Input and validation of Group reporting.
- Input and validation within Group tools including AML/CFT incidents (e.g. ‘STAR’ tool) and escalation for decision (e.g. ‘EP’ tool).
- Application of daily control reports e.g. suitability / complex products / market manipulation etc.
- Management of transactions sanctions screening (in ‘SHINE’ tool), including analysis of SHINE alerts escalated by level 1.
- Management of static data sanctions screening (in ‘SUN’ tool) escalated from the business lines.
- Issuance of Group searches.
- Issuance of compliance induction pack(s) to new employees.
- Manage and control all aspects of the financial security including AML/CFT, sanctions bribery and corruption.
Comprehensive knowledge of private banking and fiduciary products and services
Sound knowledge of the compliance related local regulations/laws
Good knowledge of financial crime, specifically around on-boarding retail and Institutional clients – KYC, EDD and AML/CFT requirements
Good computer literacy across a variety of common applications