Head of Compliance & MLRO - UK in London

The Head of Compliance & MLRO ("HCM") has responsibility for overseeing the identification, measurement, management and reporting of compliance and conduct risk, anti-money laundering, terrorist financing and proliferation financing risks ("AML/CTF/PF"), sanctions, prevention of financial crime including fraud, anti-bribery and corruption, tax evasion and market abuse. Acting as second line of defence and also undertaking the statutory responsibility of money laundering reporting duties. The HCM is also responsible for the oversight of know your customer (KYC) process throughout the Bank.

The role supports the Bank to deliver the Business Plan and strategic objectives within the context of regulatory and legal requirements, and that all commercial decisions e.g. product, market, geography, customer, scope or process, receive appropriate regulatory consideration.

Key Responsibilities

• Providing timely, accurate, and relevant regulatory advice, guidance and oversight to on compliance risks/matters.
• Serving as a first point of contact for all staff in the Bank for compliance advice, guidance and insight into regulatory issues.
• Providing accurate and timely MI to the Board, Risk & Compliance Committee ("BRCC") on a quarterly basis and on a regular basis to the relevant EXCO Committees.
• Informing staff of the compliance policies and procedures in place and communicating the impact of changing legislation/ regulation and the effect on the Bank's compliance policies, which may affect current business and future business development.
• Ensuring effective strategic and tactical compliance policies are developed and applied, with supporting procedures, and end to end processes put in place.
• Identify, assess, measure and report compliance risks and deal efficiently with it.
• Identify and investigate breaches of legal and regulatory requirements, compliance policies and procedures and ensuring that such breaches are appropriately rectified with the implementation of suitable remediation plans.
• Delivery of a risk-based compliance monitoring programme to enable the senior management to effectively understand, manage, monitor, and mitigate the Bank's various compliance and regulatory risks and that an assurance process is in place to oversee this.
• Proactive maintenance, management and update of the Bank's compliance policies, procedures and documentation in light of any statutory and regulatory developments.
• First point of contact for Regulators and statutory bodies on compliance risk matters and ensuring an open and honest regulatory relationship is maintained with the regulators at all times.
• Working closely with senior management to develop and instil a compliance culture or mind-set across the Bank providing strong compliance leadership in the Bank. Ensuring that compliance policies and procedures are embedded in the business.
• Providing compliance education and training for staff, supported by policies and procedures and other documents including compliance manuals, internal codes of conduct and practical guidelines.
• Making sure all relevant staff remain aware of their corporate and personal regulatory obligations, responsibilities and accountabilities.
• Managing and supervising the activities of other compliance function staff – Regulatory Compliance Manager, Compliance Managers and Head of KYC.
• Ensuring, from a compliance and MLRO perspective, that the Bank successfully maintain its Regulatory authorization/s.
• Ensuring that, in cases of planned absence from the office, responsibilities are delegated to approved, deputy nominated cover for the role ensuring they are trained sufficiently in advance on the tasks and responsibilities involved, including providing handover documentation to enable the replacement member/s of staff execute the role successfully.
• Participation in and involvement in training and development initiatives as directed by Head of HR and the Chief Executive Officer.
• Input into the Senior Managers & Certification Regime process, implementation, ongoing review and update in light of future developments.
• Developing and promoting a robust conduct risk culture across the Bank.
• Completion of an annual MLRO report to the Board of Directors which also includes an overview of the effectiveness of the Bank's systems and controls around whistleblowing.
• Overseeing the firm's compliance with AML/CTF/PF, Fraud, Sanctions, tax evasion, Bribery and Corruption and Market Abuse regulations.
• Management of the Bank's AML/CTF/PF processes including the design, set up and implementation of internal AML/CTF/PF procedures and policies, including customer due diligence measures, reporting, record-keeping, risk assessment, management and control systems.
• Assist Operations with the onboarding of third parties both at onboarding and periodic review for financial crime risks, procurement and operational resilience (where applicable).
• Engage with various business units to enhance operational resilience and Third-Party Risk Management practices, including proper documentation in Risk and Control Self-Assessments (RCSAs).
• Organising and arranging AML/CTF/PF training of the Bank's staff and ensuring staff complete relevant training.

Experience Required

• Technical

• In-depth knowledge and experience of: compliance Function in a financial institution, MLRO function, KYC and AML rules and regulations, PRA and FCA Regulations and UK Company Legislation.

• General experience and background experience for successful execution of the role including Banking experience, particularly in a UK-based, foreign owned institution, Emerging markets experience, Stakeholder management and engagement with senior and board level.

• Degree educated – honours level or equivalent, Relevant business experience, Member of a relevant professional institute, Postgraduate business or management qualification e.g. MBA.

• Awareness and understanding of the wider business, economic and market environment in which the Bank operates: Knowledge of the regulatory and legislative developments affecting the UK and African banking market that the Bank operates in, Knowledge of the competitive environment the Bank operates in – countries, customer and competitors – and any legal/compliance implications associated, Knowledge of the potential Financial Crime/AML/Risks inherent in the Bank UK's markets.

• Awareness and understanding of the Bank business strategy: Ensuring the business plan is compliant with the regulatory rules and regulations, Ensure that Compliance operational processes and procedures are embedded in the business model, Compliance continuity plan tested and maintained, Identify, assess, monitor, control and mitigate risks to the Bank: Annual Compliance Risk Review carried out; risks highlighted to senior management with mitigation plans provided, Oversight of know your customer (KYC) process throughout the Bank, Due diligence process in place.

• Interpret the Bank UK's financial information, to identify key issues based on this information and to put in place appropriate controls and measures: Zero Regulatory fines due to issues within remit.

• Assess the effectiveness of the Bank UK's arrangements to deliver effective governance, oversight and controls in the business and, if necessary, to oversee changes in these areas: Independent challenge and oversight is applied to the compliance policies, Ensuring the concept of independence of compliance is maintained while avoiding conflicts of interests, Oversight of compliance assurance process is in place.

• Awareness and understanding of the regulatory framework in which the Bank operates and the regulatory requirements and expectations: Ensuring the Bank is compliant with UK legislation, regulations and regulatory permissions, Input into Regulatory Reports including ICAAP and ILAAP and RRP, Horizon monitoring and regulatory radar, Comply with FCA and PRA conduct rules.

• Acts with Integrity, due skill, care and diligence, Is open and cooperative with the Regulators, Pays due regard to customers interests and treats them fairly, Observes market conduct standards, Ensures reasonable steps taken to ensure that the business of the Bank for which the Head of Compliance/MLRO is responsible for: is controlled effectively, complies with relevant requirements and standards of the regulatory system, and, any delegation of responsibilities is to an appropriate person and that the discharge of the delegated responsibility is overseen effectively, Disclose appropriately any information of which the FCA or PRA would reasonably expect notice.

Key Performance Indicators

• Prompt identification of risks.
• Timely detection of Compliance breaches and remediation of issues.
• Regulatory returns submitted on time, with no fines or breaches.
• Regulatory radar capability exists to quickly identify, assess and respond effectively to regulatory developments affecting the Bank.
• Ensuring that KYC customer checks carried out in a timely manner by staff engaging with new clients and ensuring KYC review are completed by KYC team in a timely manner.
• Timely responses to Regulators.
• Board Committee satisfaction.