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    Financial Crime Compliance Officer

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      Financial Crime Compliance Officer




      A leading financial services platform is looking to appoint a Financial Crime Compliance Officer to join its London-based compliance team.


      The Financial Crime Compliance (FCC) function forms part of the second line of defence in the Firm’s three lines of defence model.


      A critical part of FCC’s responsibilities is establishing and maintaining a robust financial crime prevention framework that suitably address the Firm’s legal and regulatory obligations and wider expectations/best practices. FCC must also ensure that the financial crime prevention framework remains effective, and therefore also provides oversight and independent challenge of first line of defence financial crime risk management activities and associated financial crime systems/controls. A core activity to achieve this is FCC’s assurance monitoring programme, through which first line of defence compliance with internal policies, standards and related procedures is assessed.


      The Financial Crime Compliance Officer will be primarily responsible for supporting the delivery of the assurance monitoring programme. This will require the identification of deficiencies in the first line of defence’s implementation of the financial crime prevention framework through performance of an annually agreed plan of assurance assignments (thematic and targeted). The issues identified, and the corresponding recommendations/agreed action plans to address deficiencies, are reported to relevant senior and executive management through formal reports. The agreed actions are monitored for completion within defined timeframes to ensure the appropriate and complete remediation of gaps is achieved; regular reporting on the progress to complete actions is similarly reported to senior and executive management.


      The Financial Crime Compliance Officer is a member of the Financial Crime Compliance (FCC) function which is part of the second line of defence. The primary objective of FCC is to ensure that the firm is in compliance with all applicable laws, regulations, and standards related to financial crime and sanctions. This is achieved through several key activities including, but not limited to:


      ● Identification of legal and regulatory obligations relevant to the firm’s business activities;

      ● Enterprise-wide risk assessment to understand the key financial crime and sanctions risks posed by the firm’s business activities;

      ● development and maintenance of appropriate policies, minimum standards, and risk determination methodologies;

      ● Providing advisory support regarding interpretation of legal and regulatory obligations, supervisor expectations and industry guidance/best practice;

      ● Investigation of internal suspicious activity reports (iSARs) and determining whether these warrant external SARs to the relevant competent authority.

      ● Providing oversight and independent challenge of first line of defence on financial crime risk management activities and associated financial crime systems/controls effectiveness.

      ● Providing training and guidance to the first line of defence on financial crime risks and control requirements.

      ● Providing regular reports to senior management and the Board of directors on the firm’s financial crime risk management regarding effectiveness of the financial crime prevention framework, and key risk indicators to support monitoring of risk exposure and appetite.


      Key Responsibilities

      Role specific:

      ● Scope and carry out reviews of financial crime and sanctions control environment through supporting delivery of the annual financial crime compliance assurance plan (“FCCAP”)

      ● Draft scoping and objectives memorandums for all allocated assignments which suitably identify the core objectives and control areas subject to the assurance review

      ● Perform mapping of key risks and legal or regulatory obligations against the processes and procedures under review

      ● Assess the design adequacy of the controls under review through mapping of keys risks and legal/regulatory obligations against the existing control environment.

      ● Test the operating effectiveness of the controls under review through designing appropriate testing programmes

      ● Identify opportunities to improve controls and related processes through applying a meticulous approach to the review and testing approach

      ● Provide robust yet professional challenge to the first line functions through applying a sceptical mindset when assessing the design and operating effectiveness of controls

      ● Present findings (interim and finalised) both verbally and in written form to relevant stakeholders both within the FCC team and the wider first line functions

      ● Prepare accurate and professionally articulated reports that describe and explain any issues identified, and the recommendations for improving associated control activities

      ● Agree appropriate actions with first line management teams, in line with FCC’s recommendations, to adequately address the issues identified and ensure the control environment facilitates management of financial crime and sanctions risks within risk appetite

      ● Ensure progress of the completion of assurance actions is effectively monitored, reported and escalated (where falling overdue, or insufficiently addressed)

      ● Ensure all work is robustly documented so that a full audit trail of the assurance review process is available, and that all working papers and other relevant documentation is saved centrally within the Team’s network folders for accessibility and recordkeeping purposes.

      ● Maintain positive and effective working relationships with the FCC team, the first line of defence functions, and other relevant stakeholders

      ● Support the delivery and ongoing development of management information and reporting relevant to FCC’s assurance programme

      ● Support the MLRO (and other Senior members of the FCC team) in developing the assurance programme, and contribute to the development of the assurance methodology and framework

      ● Support the FCC team with other responsibilities as considered necessary from time-to-time, which may include, amongst other things: (i) financial crime advisory activities; (ii) delivery of training to the first line functions; and (iii) development of management information and contribution to internal reports



      ● Ensure compliance with the company’s regulatory requirements.

      ● Adhere to the operational risk framework for the role ensuring that all regulatory or company determined parameters are complied with.

      ● Role model for demonstrating highest level standards of integrity and conduct and reflecting Company Values.

      ● At all times complying with the FCA’s Code of Conduct

      ● Ensure that you are fully aware of and adhere to internal policies that relate to you, your role or any other activities for which you have any level of responsibility.

      ● Report any breaches of policy to Compliance and/ or your supervisor as required.

      ● Escalate risk events immediately.

      ● Provide input to risk management processes, as required.


      Skills, Knowledge & Experience

      ● Good understanding of financial crime and financial services and products.

      ● Good PC operating skills,

      ● Excellent understanding of screening systems including extracting and analysing data

      ● MS Excel skills essential.

      ● Organizational and time-management skills.

      ● Decision-making skills.

      ● Understanding of performance metrics.

      ● Excellent verbal and written communication skills.

      ● Experience working in a regulated environment and knowledge of the risk and compliance requirements associated with this.


      Key Competencies

      ● A collaborative team player, approachable, self-efficient and influences a positive work environment

      ● Demonstrates curiosity

      ● Resilient in a challenging, fast-paced environment

      ● Ability to take a high level of responsibility in a fast pace and high-volume environment

      ● Excels at building relationships, networking and influencing others

      ● Strategic collaborator with insight and agility, able to anticipate future challenges, ensuring operational effectiveness.


      Additional Requirements / Conducts

      ● Act with integrity

      ● Act with due skill, care and diligence

      ● Be open and cooperative with the FCA, the PRA and other regulators (where applicable)

      ● Pay due regard to the interests of customers and treat them fairly

      ● Observe proper standard of market conduct

      Posted by

      Alison Lwin

      Financial Crime Recruiter

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