Head of Financial Crime

General Management

Reports To: Head of Operational Risk

Key Relationships: Head of Operational Risk, Group CRO, Head of ERM, Head of Insurance Risk, Entity CROs, Entity Heads of Compliance, Business Manager to the Group CRO, Controls & Compliance Assurance team, Head of Internal Audit, Chief People & Sustainability Officer, Group and Entity CUOs, other internal stakeholders including BFL Management Committee, BFL Board and Risk Committee, Beazley UK branch Senior Managers, BISIL UK branch Senior Managers, European Branch Committee members, Group, UK, EU and US regulatory authorities, financial crime regulatory agencies including OFAC, HMT, EU, external auditors and external counsel.

Job Summary: Responsible for oversight of the 2nd line financial crime team and maintaining an effective financial crime function and framework across the Group. As a leader within the 2nd Line, assist the Head of Operational Risk by delivering effective risk management strategies against financial crime risk that contribute to a robust control environment. PRA/FCA SMF17 MLRO for Beazley Furlonge Limited (BFL) and Beazley Insurance Designated Activity Company (BIdac) UK branch and all associated companies.

Key Responsibilities:

• Line management of the financial crime team, including regular team meetings, 1:1s, action setting and tracking, performance assessment and associated responsibilities.
• Member of appropriate governance forums/committees as required.
• Management of any relevant external advisors as required.
• Manage and maintain an effective Financial Crime function supporting and protecting the Group against the six pillars of financial crime risk (Bribery & Corruption, Fraud, Market Abuse, Money Laundering, Sanctions Evasion and Tax Evasion) and related reputational risk ensuring that the needs of all stakeholders are met.
• Ensure the resourcing model, quantity and quality of resources enable the Financial Crime Function to meet the group’s needs, establishing a cost-effective approach to achieving target compliance.
• Develop and maintain Beazley’s financial crime policy in line with legislative and regulatory obligations, ensuring the policy remains up to date.
• Produce regular financial crime reports and present to appropriate Boards and Committees when required.
• Advise business heads and management to focus on financial crime risk in individual business areas.
• Assist senior management in developing and maintaining an effective financial crime compliance culture.
• Ensure that the firm’s risk management policies, risk assessment profile and their application are documented and approved by Beazley’s Executive Committee and Board of Directors.
• Create and maintain a risk-based approach to financial crime, including risk assessments of Beazley’s customers, products and services, country and delivery channel risk where applicable.
• Document Beazley’s risk-based strategies in relation to financial crime compliance and the basis for the risk assessment.
• Monitor that all internal SARs received are investigated.
• Write external SARs and ensure submission to the relevant law enforcement agency for all suspicions; ensure SARs are meaningful and of good quality.
• Ensure staff are aware of their personal and regulatory obligations regarding financial crime reporting and have read and understood the firm’s policies and procedures.
• Ensure staff understand the firm’s risk-based approach to financial crime.
• Ensure role-based, competency-based training is carried out by all staff in relation to financial crime compliance, including knowledge of systems, controls and policies, with broader understanding of financial crime risks.
• Ensure all staff have access to adequate annual training in financial crime compliance risks.
• Regularly collate and provide management information to the board or executive committee.
• Write an annual MLRO report assessing the firm’s financial crime prevention controls, with management information and recommendations for improvement.
• Make appropriate and meaningful recommendations for improvement on a regular basis where deficiencies have been identified in relation to financial crime prevention controls.
• Represent the firm and interact with external agencies on financial crime matters, including regulators and law enforcement, and respond to third-party enquiries in relation to financial crime prevention, investigation or compliance in a timely manner.
• Support the Heads of Compliance in establishing and maintaining strong relationships with key regulators including the PRA, FCA, Lloyd’s, CBI, CID, and other relevant regulators and financial crime regulatory agencies including HMT/OFAC/EU.
• Establish and manage close working relationships with key internal stakeholders, providing strategic-level financial crime compliance expertise and leadership to senior management.
• Keep abreast of applicable sanctions, notices and advisories. Ensure the business and staff are aware of sanctions through training and regular communications.
• Ensure that all reasonable requests for information by regulators and law enforcement are promptly responded to.
• Promote a culture of good conduct within the Financial Crime function by demonstrating and communicating expected levels of behaviour and integrity.

Regulatory Conduct Rules: You must act with integrity; you must act with due care, skill and diligence; you must be open and cooperative with regulators; you must pay due regard to customer interests and treat them fairly; you must observe proper standards of market conduct.

Senior Manager Conduct Rules (SMF17): You must take reasonable steps to ensure the business you are responsible for is controlled effectively and complies with regulatory requirements; You must ensure that any delegation of responsibilities is to an appropriate person and that the delegated responsibilities are discharged effectively; You must disclose appropriately any information the FCA or PRA would reasonably expect notice of; and A breach of these rules constitutes a regulatory breach and will be reportable to the regulator and disclosed on references for at least 6 years.

General: Beazley core values – Being Bold, Striving for Better, and Doing the Right Thing. Employees are expected to comply with Beazley procedures, policies and regulations, undertake Beazley training, display business ethics, focus on fair outcomes for customers, and keep up to date with Beazley standards. Additional responsibilities and committee membership may be assigned.

Personal Specification

Essential Criteria:

• Proven financial crime expertise, preferably with strong understanding of the Lloyd’s market and framework.
• Regulator relations experience in an insurance-related and/or financial services organisation.
• Expert knowledge of financial crime regulation, policies and procedures, including UK/EU/UN/OFAC sanctions regimes, ECCTA, the UK Proceeds of Crime Act, FCA SYSC 6.3, FCA Financial Crime Guide Parts 1 & 2, UK Bribery Act, UK Fraud Act, JMLSG Guidance, and Suspicious Activity Reporting.
• Degree level education; and/or relevant professional qualification and experience.

Knowledge, Experience and Skills:

• Ability to build strong partnering relationships with a wide range of stakeholders.
• Ability to interact professionally and credibly with senior management and key stakeholders.
• Proven management experience with leading/ managing strategic change.
• Experience dealing with financial crime regulatory agencies in relation to sanctions (including OFAC, OFSI & EU).
• Experience working in a global, fast-paced environment.
• Experience reporting to and presenting to boards and committees.
• Proficient in Microsoft 365 apps.

Aptitude and Disposition:

• Strong leadership and people management skills; risk-based judgement; maintained confidentiality, diplomacy and discretion; influencing and trusted advisor; flexible; energetic, enthusiastic and positive; self-motivated with ability to work autonomously; highest integrity/discretion; strong written and verbal communication; analytical; attention to detail with big-picture viewpoint; ability to challenge, negotiate, influence and persuade internal and external parties.