Head of Compliance and MLRO

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United Kingdom & ROI
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10.05.2018 11:02 AM

Responsible for meeting Regulatory Requirements for the Bank, its branches and subsidiaries and perform duties of MLRO: Advising, Supporting & Executing Activities re Fighting Financial Crime (KYC / AML / Client Take On/Bribery), Treating Customers Fairly (COBS, CASS, COLL) and maintaining integrity in dealings (Chinese walls, clear communication, complaints handling, etc.).

Responsibilities: (Day-to-day duties)


  • Develop and implement the compliance strategy to meet the Regulatory requirements.
  • Prepare and undertake a risk-based annual Compliance Monitoring Programme and report any deficiencies to Senior Management, i.e. COBS, CASS, Financial Crime, TCF, etc. (e.g. financial promotions, best execution, market abuse, conflicts of interest/Chinese walls, insider dealing, record-keeping, inducements, etc).
  • Maintain Compliance Record-Keeping, e.g. Gifts, PAD, Complaints Register, FCA/PRA registrations, etc.
  • Actively support and advise the Business and Senior Management on the relevant Regulatory developments and requirements.
  • Assist the Bank in understanding and addressing all applicable regulations.
  • Develop, maintain and enhance the compliance policies, procedures, processes and ensure Compliance Manual is updated.
  • Develop the procedures and controls for the Compliance Department.
  • Ensure global consistency and high quality standards in accordance with the Group Policies.
  • Keep Senior Management and/or the Board of Directors notified as to applicable returns to be completed and timeframes for submission to the FCA/PRA/other Regulators.
  • Assist Senior Management in liaison with Regulatory agencies, and internal and external requirements on compliance related matters (namely AML/KYC, COBS, CASS, COLL). Ensure Senior Management are notified of external requests for consideration prior to responding.
  • Ensure appropriate open relationships maintained with the FCA/PRA and other regulators through completion and submissions of all applicable returns, including transactions reporting requirements.
  • Work closely with management to establish an appropriate compliance culture throughout the Bank including the development of specialised training programmes.
  • Ensure Client Due Diligence is robust and where shortcomings are identified, manage and implement respective remediation measures and actions.
  • Provide training on Compliance related matters to Business, e.g. AML, COBS - Conflicts of Interest, Market Abuse, Insider Dealing, ABC, etc., CASS & COLL.
  • Report monthly to the CEO and regularly to Senior Management on Compliance related matters, e.g. regulation changes, AML, compliance weaknesses and action being undertaken, etc.

Adheres to those responsibilities as defined in the individual signed statement of prescribed responsibilities and in respect of the Senior Management Regime.

Responsibilities: (Day-to-day duties)


  • Act as the MLRO for the Bank.
  • Develop and implement the compliance strategy to meet the Regulatory requirements, e.g. Anti-Bribery and Corruption (ABC) Programme, AML, KYC, etc.
  • Review AML requirements and ensure implementation of AML systems and controls.
  • Draft and update AML policies and procedures, including the AML Handbook.
  • Administer the Bank’s sanctions programme and make disclosures to the Asset Freezing Unit as and when necessary.
  • Receive internal disclosures of suspected money laundering or terrorist financing.
  • File Suspicious Activity Reports (SAR) to SOCA where the grounds for suspicion are sufficient and liaise with SOCA to deal with such matters as consent to proceed with a transaction and other disclosure issues, particularly with regard to clients or third parties.
  • Assess the AML risks linked to the Bank’s client portfolio and conduct daily transaction monitoring.
  • Implement Customer Due Diligence measures.
  • Manage all aspects of client on-boarding and KYC processes in Central Client, including the release of data into operational systems.
  • Ensure that periodic client reviews are completed by Front Office in a timely manner.
  • Maintain client records.
  • Organise and arrange anti-money laundering training for staff.
  • Advise and disseminate information to business units of proposed or pending regulatory changes.
  • Advise and guard against tipping-off or prejudicing an investigation once a SAR has been made.
  • Prepare annual MLRO report to Audit Committee, in addition to quarterly updates as requested,
  • Supervise AML systems and controls in Paris branch through monthly reporting.


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